Response to Comment (By Author)

Period Dates: Generated: 9/16/2014 11:18 AM

Comment Period:

Project:

Notice of Availability - DEIS 

comment period

10C Designated Routes Project (34220)

10/26/2012 - 1/24/2013

Author(s) Comment Response

Adams, Louann The Forest Service needs to start from scratch to develop new 

alternatives that will provide maintenance of the OHV trailriding experience.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author) 1 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Adams, Louann The value of the trail riding experience is not found by wide 

connecting roads (i.e. whoop roads).

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Adams, Louann Protect our families and don’t let them close down more 

acreage in our dunes.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Adams, Louann We need these large riding areas to support our families and 

the economies around these areas.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 2 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 3 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Adams, Louann The companies in these small communities around our dunes 

need the business brought in by fellow riders to stay afloat. 

By closing our dunes you will be hurting a lot of people, those 

being supported by atv riders and also the families of off road 

riders.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 4 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Adams, Louann The proposed actions are detrimental to the health of the 

sports and economy on the Oregon coast that rely on these 

areas, not to mention the safety and enjoyment of the clubs, 

people, and families that currently use the dunes for 

recreation.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 5 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Adams, Louann The Forest Service needs to start over in their assessment to 

develop new alternatives to provide reasonable solutions that 

will accommodate the user experience and protect the 

wetlands and vegetation

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Alderson, George We are opposed to opening any additional ORV areas or trails, 

carved out of the nonmotorized zone

Changes to areas managed as non-motorized use are outside

the scope of this project. Therefore none of the proposed

routes or reallocations are in non-motorized areas. The only

area being considered for route designations and reallocations

to open riding are currently in Management Area MA 10 (C),

open to OHVs on designated routes only.

Alderson, George The Forest Service should not reward ORV riders who chose 

to ride outside the approved areas and routes by approving 

new areas for them to ride, at the expense of other public 

values such as wildlife habitat and quiet recreational uses.

Thank you for your comment. Please refer to the wildlife

analysis in Chapter 3 of the FEIS.

Alderson, George We favor the designation of a reasonable, well demarcated 

system of ORV routes through the vegetated areas of the 

Oregon Dunes.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 6 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Alderson, George We oppose an expansion of “open” riding areas. Restricting or reducing the number of acres managed for OHV

use at the ODNRA is outside the scope of this project. The

purpose and need of this project is to designate routes within

MA 10 (C). Approximately 46% of the ODNRA is managed for

OHVs to some degree. Of that 46%, about 21% is managed

for open riding in areas of open sand and 4,455 acres or 15%

are managed for OHVs on designated routes only. This

project addresses only those 4,455 acres. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 7 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Alderson, George ORV open areas should be restricted to unvegetated dunes, The 1994 Dunes Plan describes management areas wherein

OHV use is permitted. Areas of the ODNRA open to cross

country OHV travel are in Management Area 10 (B), which is

primarily open sand. The Dunes Plan also directs that OHVs

will be permitted in some vegetated areas, but restricted to

designated routes in the vegetated areas known as MA 10

(C). The primary purpose of this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA, as directed by the 1994 Plan. 

Additionally, some vegetated areas wherein OHVs are

restricted to designated routes are dominated by non-native

vegetation. The intent of this project is not to protect nonnative vegetation. Therefore, four alternatives to the proposed

action suggest reallocating areas of MA 10 (C) to open riding. 

Additionally, some areas currently allocated as MA 10 (C) are

proposed for reallocation to open riding. The rationale for

those reallocations can be found in Chapter 2 of the DEIS and

FEIS.

Conversely, the Dunes Plan also identified areas of open sand

that wherein OHVs would not be permitted. Examples include

the areas west of the Oregon Dunes Day Use Area, and the

Tenmile Creek Research Natural Area (RNA). No reduction in

acres within areas managed for non-motorized activities are

proposed in any of the alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 8 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Alderson, George large areas of the open sand should be zoned for 

nonmotorized recreational activities

Restricting or reducing the number of acres managed for OHV

use at the ODNRA is outside the scope of this project. The

purpose and need of this project is to designate routes within

MA 10 (C). Approximately 46% of the ODNRA is managed for

OHVs to some degree. Of that 46%, about 21% is managed

for open riding in areas of open sand and 4,455 acres or 15%

are managed for OHVs on designated routes only. This

project addresses only those 4,455 acres. 

Alderson, George Don’t let this plan be overly weighted toward ORV activities, 

but include a strong program of ecological restoration as 

provided for in the 1994 Oregon Dunes Plan.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Alderson, George Keep ORVs out of areas of native vegetation and wetlands, 

and protect and restore these habitats.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Alderson, George Tell ORV riders where they may ride by installing clear 

signage and sturdy, wildlife-adapted fencing.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 9 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 10 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Alderson, George create effective deterrence against rogue ORV riders by 

putting law enforcement officers in the field at times when 

violations are most likely, especially at the start of the riding 

season.

Law Enforcement Officers work varied schedules at the

ODNRA. The OHV crew also work in the field throughout the

year, with additional crew members hired during the summer

season.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 11 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Alderson, George Beale Lake: maintain the protection of the 10F designation. Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Alderson, George Tenmile RNA and Snowy Plover critical habitat: delete the A16 

open riding area.

The boundary line separating the Umpqua riding area and the

Tenmile Research Natural Area (RNA) is posted as closed to

OHVs with signs on wooden posts. During field observations

over that last eight years, this line of staggered signing

through the open sand of MA 10 (B) has been an effective

deterrent to OHVs. The only user-created route entering the

RNA from the area south of A16 has been barricaded at the

Coos/Douglas County line and has been monitored for the

past four years.

Alderson, George Horsfall Lake: adopt Alternative 3 to better protect riparian 

and natural values

Action alternatives 2, 3 and 4 propose no designated routes or

reallocations near Horsfall Lake.

Alderson, George Area 14: delete this area to provide better protection for 

predominantly native vegetation.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 12 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Alderson, George The continued use of ORVs in the Oregon Dunes inevitably 

reduces the opportunities for the public to enjoy nonmotorized 

forms of recreation. The noises of ORVs drive visitors away 

from areas where they are used, and in vegetated areas their 

impacts prevent the native ecosystem from fully recovering.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Alderson, George the approved areas and trails should be reduced, Reducing open riding areas of MA 10 (B) and reducing the

miles of existing designated routes within MA 10 (C) is outside

the scope of this project.

Amador, Don The purpose of this letter is to request that you withdraw the 

current DEIS and associated public comment period and 

conduct supplemental analysis and issue a supplemental EIS, 

to include and seek input on additional alternatives to those 

presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 13 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 14 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Amador, Don The DEIS is flawed because it failed to substantively analyze 

and or address those issue areas which include; Public Law 92

-260, NEPA analysis, loss of OHV opportunity, confused 

zoning, counterproductive details in scoping, outofdate/defective/non-relevant 1994 Dunes Plan, 

"minimization", impacts to upcoming forest plan revision, 

coordination with counties, environmental justice, purpose 

and need, impacts to local economies, vegetation 

management, and loss of agency credibility in the community.

Please refer to the responses to comments on pages 21-30 of

Appendix A, that respond to NEPA compliance, loss of OHV

opportunity, public participation, Forest Plan revision, public

involvement and vegetation management.

Amador, Don BRC believes the Forest has illegally narrowed the Travel 

Planning analysis through generation of arbitrary "sideboards" based on an out-of-date 1994 Dunes Plan. This will 

create inadequate long-term OHV opportunity from improper 

"filtering" of possible alternatives. These sequential limitations 

cumulatively leave the Forest with an unduly narrow range of 

options in the DEIS. In generating its proposal, the Forest 

largely ignored past mapping and input from the public.[...]

Even where routes or areas do not meet the 1994 Dune Plan 

direction, the agency should at least consider whether a plan 

amendment is justified to modify the 1994 Dunes Plan 

direction. In fact, through the current project-level planning 

the agency may appropriately and logically determine that 

new routes and areas would be superior to those identified in, 

or limited by, the previous plan.

Please refer to FEIS, Chapter 2 Alternatives. Alternatives 2,

4, and 5 all propose rezoning to one degree or another areas

that are zoned Management Area 10C - OHVs on Designated

Routes Only to Management Area 10B - Open Riding.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 15 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Amador, Don No formal consultation with counties is noted. The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Amador, Don BRC believes the OHV recreation has already been 

"minimized" enough by previous NEPA decisions. In 1972, 

approximately 28,000 acres were open for legal OHV use. 

After implementation of the 1979 ODRNA Management Plan, 

the acreage available for OHV use was reduced by about 47% 

down to 15,000 acres. When the 1994 ODNRA Management 

Plan was adopted, the acreage available for open riding was 

reduced significantly to 5,930 acres. The agency in Zone 10 

(C) attempts to create the illusion that 4,455 acres of 

designated routes are available for OHV use. However, since 

only about 10 miles of designated routes exist in Zone 10 (C) 

that acreage is reduced to less than an acre (actual land 

footprint of the routes). Between 1972 and 2011, the acreage 

available for open OHV use has been reduced from 28,000 

acres down to just below 6,000 acres. Just 20 percent of the 

NRA is available for legal OHV use

today.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 16 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 17 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 18 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 19 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 20 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Amador, Don Aside from providing a quality user experience, a return to 

historical locations of vehicle access will actually assist in 

meeting management objectives.

The Dunes Plan specified that MA 10 (C) areas be managed

to "protect vegetated habitats while providing controlled

opportunities for off highway vehicle touring and traveling on

designated routes." Reallocations from MA 10 (C) to open

riding were proposed in Alternatives 2, 4, Modified 4 and 5 in

response to scoping comments that described the importance

of the trail riding experience in a quality OHV experience at

the ODNRA.

Amador, Don In making this observation, we specifically note that many of 

the minimization criteria are implicated by and may have been 

inadequately discussed in the DEIS, including vegetation, 

wildlife and wildlife habitat, and conflicts among different 

classes of motor vehicles.[...]SEIS would allow the agency to 

more thoroughly address the minimization issue. A more 

robust analysis will not only better insulate the final decision 

against challenge, but should, in fact, allow for options which 

expand areas or opportunities for OHV recreation based on 

previous NEPA decisions that unduly "minimized" OHV use.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 21 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 22 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 23 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 24 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 25 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Amador, Don Again, Section 12 of the Act directs the Secretary of 

Agriculture to establish and Advisory Council to consult with 

on a periodic and regular basis with respect relating to 

management and development of the recreation area. This is 

an independent statutory obligation essentially ignored by the 

agency for the last 25 years. Thus, the Forest Service has 

been illegally managing this area without the input of this 

council. The lack of input from this council could explain the 

significant loss of motorized access to the NRA in both the 

1979 and 1994 Management Plans. The restrictions of the 

1979 and/or 1994 actions are, in hindsight, illegal, and should 

not form the baseline or be otherwise presumed legitimate in 

the current planning effort.

The 2009-2010 Working Group which did not fall under the 

rules and regulations of the Federal Advisory Committee Act 

(FACA) is not a legal or practical substitute for a formal 

advisory council- per the 1972 Act- that falls under FACA rule. 

In addition to complying with FACA, a valid advisory council 

must comply with specific direction in the Act, such as 

including members appointed by the Governor and each 

county within the NRA.

A SEIS would allow for the agency to analyze creation of an 

advisory council in full compliance with the Act, FACA, and 

other applicable law.[...]Early in the process and the Forest 

should have seized the opportunity to form an advisory 

council and issue a revised NOI that better considers the input 

of the council and public and provides a starting point for a 

broader, better supported and more effective management 

strategy.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 26 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Amador, Don Vegetation and dune management should dovetail with 

recreation management as part of a coordinated strategy.[...]

The project should address active and effective vegetation 

management alternatives, which can complement, and 

potentially be enhanced by, effective recreation management. 

In short, the Oregon Dunes present a unique situation where 

active sand dunes should be a desired condition and 

encroachment of non-native vegetation is a "significant issue" 

to be addressed.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Amador, Don The DE IS is fatally flawed since it is based on the 1994 Dunes 

Plan, which was created without legally required input from a 

NRA advisory council. Also, the1994 Plan is well beyond its 

useful period of 10-15 years as identified within the plan. The 

plan also states that the Forest Supervisor shall review the 

plan every five years to determine if conditions or public 

demands have changed significantly.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective on June 10,

1977, in accordance with the provisions of the federal

Advisory Committee Act (FACA) of 1972 (Public Law 92-463).

The Dunes Plan was prepared according to Secretary of

Agriculture regulations (36 CFR 219) which are based on the

Forest and Rangeland Renewable Resources Planning Act

(R_A) as amended by the National Forest Management Act of

1976 (NFMA). The Dunes Plan was also developed in

accordance with regulations (40 CFR 1500) for implementing

the National Environmental Policy Act of 1969 (NEPA).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 27 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Amador, Don The timing of this project is suspect since a Forest revision is 

scheduled for 2014. BRC is concerned this project may frontload or taint the upcoming revision with a redetermined 

"closure-oriented" outcome and/or restrict active management 

options (including reopening some areas to "Open OHV" use) 

to help arrest the spread of non-native vegetation into the 

sand dunes .[...]The DEIS failed to analyze and disclose the 

project's impacts on the Forest revision. A SEIS would allow 

the agency to analyze that important issue.

At one time the Siuslaw national Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Amador, Don The attached county resolution(s) are evidence the agency 

failed to coordinate with affected counties in this EIS and the 

1994 Dunes Plan. BRC wants to ensure the ODNRA is 

following administration directives and has actively considered 

designation of federal and non-federal cooperating agencies in 

the preparation of analyses and documentation required by 

the National Environmental Policy Act (NEPA), and to ensure 

that Federal agencies actively participate as cooperating 

agencies in other agency's NEPA processes. The CEQ 

regulations addressing cooperating agencies status (40 C.F.R. 

§§ 1501.6 & 1508.5) implement the NEPA mandate that 

Federal agencies responsible for preparing NEPA analyses and 

documentation do so "in cooperation with State and local 

governments" and other agencies with jurisdiction by law or 

special expertise. (42 U.S.C. §§ 4331(a), 4332(2)). Failure to 

formally consult with

the County [Counties] precludes the agency from meeting its 

statutory mandate. These directives are in addition to the 

specific direction of Section 12 and 14 of the Act requiring 

cooperation with the State and counties.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 28 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Amador, Don create new alternative(s) and/or modify alternative 5 that 

might help the agency and the public meet the current 

purpose and needs of the resource and community.

Action alternatives 2, 3, 4, Modified 4 and 5 meet the purpose

and need for this project which is to complete the designation

and development of an understandable, manageable and

environmentally sustainable system of OHV routes to provide

for access and enjoyment for recreational visitors. (FEIS, p.

12)

Anderson, Christian The Forest Service needs to start from scratch to develop new 

alternatives that will provide maintenance of the OHV trailriding experience.[...]The preferred alternative (4) closes 62% 

of trails (84 miles closed out of 135 miles) --- unacceptable.

[...]The Forest Service needs to start over in their assessment 

to develop new alternatives to provide reasonable solutions 

that will accommodate the user experience and protect the 

wetlands and vegetation, which may include opening more 

"open areas" to OHV use, or formulating a plan for the 

creation and maintenance of a designated trail system.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 29 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Anderson, Christian The value of the trail riding experience is not found by wide 

connecting roads (i.e. whoop roads).

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Anderson, Christian The proposed actions are detrimental to the health of the 

sports and economy on the Oregon coast that rely on these 

areas, not to mention the safety and enjoyment of the clubs, 

people, and families that currently use the dunes for 

recreation.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 30 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Anderson, Christian The trails in question have been around for decades, and 

while the 10c management plan calls for "controlled 

opportunities" for OHV use, the plan did not accommodate the 

growth of the various OHV users of the ODNRA.

The 1994 Dunes Plan directs management of MA 10 (C) .

The Dunes Plan was developed to meet the requirements of

National Forest Managment Act (1976). Proposed projects

must, by law, meet the direction of the Dunes Plan. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 31 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Anderson, Jason The Forest Service needs to start from scratch to develop new 

alternatives that will provide maintenance of the OHV trailriding experience.[...]The Forest Service needs to start over in 

their assessment to develop new alternatives to provide 

reasonable solutions that will accommodate the user 

experience and protect the wetlands and vegetation, which 

may include opening more "open areas" to OHV use, or 

formulating a plan for the creation and maintenance of a 

designated trail system.[...]The preferred alternative (4) 

closes 62% of trails (84 miles closed out of 135 miles) --- 

unacceptable.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Anderson, Jason The proposed actions are detrimental to the health of the 

sports and economy on the Oregon coast that rely on these 

areas, not to mention the safety and enjoyment of the clubs, 

people, and families that currently use the dunes for 

recreation.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 32 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 33 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Anderson, Jason The value of the trail riding experience is not found by wide 

connecting roads (i.e. whoop roads).[...]The trails in question 

have been around for decades, and while the 10c 

management plan calls for "controlled opportunities" for OHV 

use, the plan did not accommodate the growth of the various 

OHV users of the ODNRA.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 34 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Applebee, Cal The Florence Area Chamber of Commerce is opposed to the 

USFS proposed closure options as contained in the current 

draft environmental impact study on the ODRNA I Oc 

Designated Routes Project.

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Applebee, Cal We feel there are many inaccurate findings regarding the 

economic impact on the proposed c losures contained in the 

study: out of a 152 page document that allegedly addresses 

the overall impacts, with only five pages, (14, 15, 137, 138 & 

139) addressing economic impacts vs. the exhaustive detail of 

environmental impacts, the study ofthe economic impact is 

clearly not adequate.[...]While we a11 cherish and wish to 

preserve the Oregon National Dunes as it is in our own back 

yard, it is that fact as we11 that makes it a tremendous 

resource for our economy a lso

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 35 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Applebee, Cal Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 36 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the reference on page 137 that " ... ODNRA contributes about 

$2.5 million annually to the three counties within which the 

ODNRA is located (Coos, Douglas and Lane). It accounts for 

about 82 jobs within the three-county area" we feel is

simply not accurate- there are probably in excess of 82 jobs 

alone just within the Florence area that are directly related to 

the use of the dunes.

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 37 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Aust, Shawn The timing of this project is suspect since a Forest revision is 

scheduled for 2014.

At one time the Siuslaw National Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Ballenger, Bob Alternative #3 is my choice. Thank you for your comment.

Ballenger, Bob It seems to me you are constantly thinking of ways to remove 

OHV riding areas, even as the sport increases in popularity.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 38 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 39 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 40 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 41 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 42 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Barkley, Scott Think of all the revenue you will be losing if you continue to 

target closing dune areas.

Revenue is not a consideration in fulfilling the Forest's legal

obligation to designate routes in MA 10 (C). The Forest is

fulfilling the requirement of the 2005 Travel Management Rule

and the direction of the 1994 Dunes Plan by completing this

project. 

Barkley, Scott these trails that you are proposing to close are trails that we 

use to get away from the big crowds and teach our learning 

riders how to be responsible users of the dunes.

Alternatives 2, 4, Modified 4 and 5 propose reallocating areas

to open riding to provide a trail riding experience. Those

alternatives were developed in part from public comments

asking that the Forest provide a trail riding experience in

addition to designated routes and from comments that

expressed that a trail riding experience is not provided

by designated routes. In Modified Alternative 4, A3 was

modified to include areas that commenters on the DEIS

identified as areas wherein families could enjoy an area away

from crowds.

Barkley, Scott The Forest Service needs to start from scratch to develop new 

alternatives that will provide maintenance of the OHV trailriding experience. The value of the trail riding experience is 

not found by wide connecting roads (i.e. whoop roads)

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 43 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Blanton, Robin All the trails would be missed due to the lack of activities 

around as well as local businesses that thrive only on out of 

towners.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 44 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Bogan, Timothy I do not support any of the 5 options listed in the above 

referenced environmental impact study that includes closing 

the riding trails through non sensitive areas.

Other concerns in addition to the existence of sensitive plants,

animals or habitats were considered in proposing designated

routes and areas open to OHV travel. For example, some

areas of MA 10 (C) that are dominated by non-native

vegetation do not have proposed routes or proposals

to reallocate them to open riding in order to reduce user

conflicts. In particular, areas near communities and areas near

non-motorized recreational opportunities were not proposed

for trails or open riding in order to reduce noise impacts. 

Bogan, Timothy The ODNRA was established to "provide for the public outdoor 

recreation". When the act was

written in 1972 the designated areas were predominantly 

open riding dunes. This includes the

areas where most of the riding trails exist today. There is no 

basis in claiming that because the open areas are now 

overgrown with non native vegetation that the original intent 

to provide

recreation use no longer exists. In fact it does. These trails 

are a part of the original open riding areas and should not be 

subject to closure because they are not now a "designated 

route".

H.R. 8763, established the Oregon Dunes National Recreation

Area in order "to provide for public outdoor recreation use and

enjoyment of certain ocean shorelines and dunes, forested

areas, fresh water lakes, and recreational facilities..." Please

refer to Response #142 for a discussion of open dunes in

1972, and 1979 when the first Dunes Plan was released as

compared to current conditions. 

Bogan, Timothy Because the Forest Service failed at its responsibilities to do 

so we have lost significant areas of open dunes since 1972. 

To this day I note no efforts to do this.

Please refer to Resonse #3 for more information on dune

restoration, and to Response #142 for more information of

existing open dunes in 1972 as compared to today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 45 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Bogan, Timothy The Forest Service has failed in its management of the 

ODNRA by not complying with Congress'

Act to "conservation of scenic, scientific, historic and other 

values contributing to public

enjoyment of such lands".

The Forest has managed the ODNRA in complaince with the

act establishing the Dunes in 1972.

Bogan, Timothy Change all areas designated lOc to lOb. The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Bogan, Timothy reopen the ORDNA area between Spinreel and the southern 

boundary of the Winchester dunes to offroad riding.

It is outside the scope of this analysis to rezone any areas not

within Management Area 10 (C).

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 46 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Oregon Dunes National

Recreation Area currently has about 34 miles of designated

trails and about 5,930 acres of designated areas for open

motorized travel. As the Siuslaw National Forest developed its

2009 Travel Management Plan, it became apparent that since

not all the MA 10 (C) routes had been designated, some areas

within the motorized portions of the ODNRA were largely

inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10C to motorized cross-country travel and

allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Three alternatives (2, 4, and 5) analyze rezoning Management

Area 10C (designated routes only) to Management 10B (open)

in varying degrees. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 47 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Bogan, Timothy stop wasting taxpayer money and time with these 

obstructionist initiatives and commence the work of managing 

the ORDNA by eradicating invasive species and providing for 

greater recreational use.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Bogan, Timothy The Forest Service cannot deny the potential liability that 

comes with eliminating a significant portion of riding areas 

confining the growing number of riders to smaller riding 

areas.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 48 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Bogan, Timothy One of the options should have been to re-designate the 10c 

areas of the dunes to lOb with the

exception of wetland areas and areas where there may be 

sensitive species.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Bogan, Timothy The status quo, arguably, has worked. For nearly 20 years the 

Forest Service has not seen fit to do anything about the riding 

trails. As a matter of fact, there is no compelling reason 

whether endangered species, environmentally sensitive areas 

or otherwise that the Forest Service felt compelled to do 

something now. This project is only being done to keep 

government personnel busy, to justify their positions and 

management.

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. Designating routes and areas

as open or closed to motorized vehicles is directed by the

Travel Management Rule.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 49 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Bogan, Timothy Some of the positions the Forest Service has taken on the 

project are that there is no funding to maintain the trails or to 

police the trails for public safety issues.

 

The Forest recognizes the need for upfront education and

enforcement of the designated routes decision to inform OHV

riders of routes open to motor vehicle use. Enforcement of the

trail system will be improved through signage, unauthorized

route closure, and regular patrols. Public compliance is

expected to increase with the formal designation of a more

understandable trail system connecting OHV riders to

beaches, open sand areas, and designated sand camps. Trail

operation and maintenance will be funded through Forest

Service appropriated funds, recreation fee revenues

generated in the Oregon Dunes NRA, and partnership funds

from the Oregon Parks and Recreation ATV grant

program. Cooperative law enforcement will continue to

address public safety issues. 

Bogan, Timothy Closing the trails system forces more riders into the open 

dunes at any given time. This in itself is a major public safety 

hazard as the majority of the injury related accidents occur on 

the open riding areas of the dunes.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Bogan, Timothy If the Forest Service were to close the trails, that more than 

anything will be impossible to police. Riders are going to cross 

barriers and never be caught.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 50 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 51 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Bogan, Timothy If anything the Forest Service should seek to be restoring the 

dunes to the state in which it was received in 1972.[...]For 

example, the dunes between Spin reel and the southern 

border of the Winchester Dunes are slowly dying off as the 

Forest Service has failed to eradicate invasive species and 

doesn't allow motor vehicle use. Now there's something to 

strive for in fixing.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 52 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Bogan, Timothy Further, as it was designated a "National Recreation Area" 

tasking the Forest Service with developing opportunities for 

use, the Forest Service should be seeking to expand riding 

opportunities.

The primary purpose and need for the Project is to complete

the designation and development of a comprehensive,

understandable designated OHV route system that can be

effectively managed and maintained within the MA 10 (C)

areas of the ODNRA. Alternatives 2, 3, 4 Modified and 5

would expand the miles of designated routes in the ODNRA.

Alternatives 2, 4 and 5 would reallocate acres to open riding

as MA 10 (B) , thus expanding OHV trail riding opportunities.

burchfield, jamey I would like to ask that you continue to do your best and not 

reduce motorized recreation areas, but rather create 

additional outdoor opportunities.

Thank you for your comment.

Butterton, Gordon consider keeping access to the many trails that follow the 

western edge of the dune area accessed from Hauser & 

Horsefall.

Many trails in the western portion of the South Riding Area are

within MA 10 (B), and will not be affected by this project.

Camden, Dan Having more area to ride is important in that there is always 

something new and

exciting to find, as well as keeping the terrain from getting so 

rough from all the traffic that being concentrated into a 

smaller area would cause.

Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Camden, Dan The other problem with the available riding area being 

reduced is that traffic would increase and when you put more 

people on a smaller amount of trails the possibility of injury 

goes up.

Rider safety is discussed in Chapter 1 under "Issues" in the

DEIS and FEIS.

Camden, Dan We do not agree with any of the proposed alternatives in the 

DEIS and would ask that the

Forest Service start from scratch and develop new 

alternatives.

Please refer to Response #9 for a discussion of the

development of alternatives in the DEIS and FEIS.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 53 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Camden, Kyle Having more area to ride is important in that there is always 

something new and

exciting to find, as well as keeping the terrain from getting so 

rough from all the

traffic that being concentrated into a smaller area would 

cause.

Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Camden, Kyle The other

problem with the available riding area being reduced is that 

traffic would

increase and when you put more people on a smaller amount 

of trails the

possibility of injury goes up.

Rider safety is discussed in Chapter 1 under "Issues" in the

DEIS and FEIS.

Camden, Kyle We do not

agree with any of the proposed alternatives in the DEIS and 

would ask that the

Forest Service start from scratch and develop new 

alternatives.

Please refer to Response #9 for a discussion of the

development of the alternatives DEIS and FEIS.

Caplan, James First, concerning your current DEIS process, it might be 

advantageous to suspend this effort, address several land-use

-designation concerns raised by the riders (and presumably 

others) in your Forest Plan revision, and complete the trailsdesignation effort either concurrently with or after the revision 

is done. Almost twenty year have passed since the Dunes was 

last zoned. Science, technology, use, and public concern and 

advocacy have all changed considerably. It might make sense 

to fold some of your current issues into a broader and more in

-depth land-use consideration process.

At one time the Siuslaw national Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Caplan, James Second, the Siuslaw has an enviable record of public 

collaboration on many sensitive issues, including stewardship 

contracting in pursuit of forest restoration. For whatever 

reason, that intensity of collaboration seems to be missing in 

The Forest followed laws, policies and regulations in soliciting

input for this project. The Siuslaw National Forest began

seeking information from the public in regard to the

Designated Routes project in 2009, when the Forest hired an

independent contractor to assemble and facilitate a working

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 54 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the Dunes DEIS process. As I have heard, perhaps it existed a 

few years ago but faded for some reason.[...]As a far-off 

observer, it strikes me that preserving that collaborative 

culture is at least as valuable as completing the Dunes DEIS 

at this time.

And, as a second observation, for whatever reason the 

Siuslaw leadership is serving as intermediary and arbitrator 

between and among environmentalists, internal advocates, 

community voices, and the riders. The statement conveyed to 

Gary from one of your staff, “We’re bound to get sued,” is a 

pretty clear indicator of this “Triangulation Dilemma”—one 

that frequently faces the Forest Service. And a dilemma you 

also seem to be caught in.

So, as you move to the FEIS, wouldn’t it also be prudent to re

-engage your working group or another collaborative effort 

with all parties at the table? You have competent staff who 

could do this. Or, if an outside facilitator would be a better 

choice, many good ones live and work in the Eugene area.

An intense day or two of problem-solving work with 

representative parties at the table might resolve most issues, 

get the Forest Service out of the triangulation straitjacket, and 

greatly bolster the social, political, and legal defensibility of 

your FEIS. I would suggest that to the extent you can let the 

various publics, working together, design your preferred 

alternative.

Most importantly, you might be able to get the participants to 

focus beyond your current issues and mutually commit to 

effective restoration strategies. As you know, environmental 

interests usually depend on government for such things. The 

group of individuals with varied interests in the Oregon Dunes.

In 2010, this working group provided ideas regarding a system

of designated trails and open riding areas that they believed

would meet the 1994 Dunes Plan. The results of their work

was posted to the Forest website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 130 comments on the DEIS.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 55 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

riders who may have a willingness to invest time and treasure 

are turned off and away by the conflict. And community and 

business interests have few resources to invest in something 

like dunes restoration in these difficult economic times.

Your present course seems not likely to get you to 

collaborative restoration. Could there be another approach 

that would work?

Caplan, James Third, as I mentioned to your folks at the January 10 meeting, 

I’m concerned that designating trails under Washington Office 

direction doesn’t apply well to annually (maybe monthly) 

moving or dynamic landscapes. In this sense, the dunes 

represent a land-management challenge much like permitting 

grazing on transitional range.

In many parts of the country, including on the Umpqua 

National Forest, cattle grazing may occur in temporary 

openings and grasslands that derive from other activities: 

logging, wildland and prescribed fire, and road removal, to 

name a few. Grazing on a specific site may occur for a few 

years, or even a decade, but then gradually disappear as 

changing vegetation moves the site away from grassland.

The dunes are always moving, in open spaces, among the 

trees, and across beach grass and shrub sites. So also it 

appears that the riders follow naturally changing riding 

opportunities in sanded areas, driving on what might be called 

“transitional trails.”

This is not a situation anticipated particularly well by the 

Washington Office ATM direction, which purpose is to prevent 

indiscriminate cross-country riding to prevent resource 

Since the 1994 Dunes Plan, the Forest has managed

approximately 33 miles of designated routes within MA 10 (C).

The management challenge associated with these routes

through vegetated habitat has been brushing and grooming

the routes. These trails are not in environments of open

dunes and shifting sand. More transitional trails within the

more dyanamic environment of the open dunes are in

Management Area 10 (B), open riding, and are not actively

managed as designated routes. As directed by the 1994

Dunes Plan, designated routes within MA 10 (C)

should connect open riding areas or open riding areas to the

beach. 

Some areas of MA 10 (C) that are primarily dominated by nonnative vegetation, among other rationale including potential for

user conflicts with non-motorized recreation and noise impacts

to local communities, and that provide a trail riding experience

have been proposed for reallocation in Alternatives 2, 4,

Modified 4 and 5 to open riding. Trails in those areas will not

be managed as designated routes. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 56 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

damage. So, the WO direction focuses primarily on 

designating established, well-defined riding trails “open” and 

“closed” for the rest.

You are faced with a significantly more fluid situation than the 

WO direction anticipates. So, I believe you could respond in a 

more fluid way, too, particularly given the NRA designation. 

While protecting key natural features such as native 

vegetation and wetlands through public education, sitesignage, and mapping, you could also allow for remaining 

areas to be open.

If you adopt a fluid approach, it might be worth an annual 

spring field trip with interested members of your putative 

collaborative group to get the locations and boundaries nailed 

down. Once established, riders would be free to use the 

remaining areas, even those outside the open dunes. In 

addition, by employing the riding community in establishing 

and maintaining the annual no-ride boundaries, you would 

promote self-regulation and cooperation.

carlson, derek My family has been traveling to the Oregon dunes from 

California for years. We spend a lot of money on our way 

there and while we spend our 2 weeks there. It would be a 

shame for even more areas to close because of an outdated 

plan that possibly made sense back in 1995. Ohv's are a huge 

tax revenue in every state with less and less areas to ride 

every year.

Thank you for your comment.

Christensen, Brent Employment for hundreds of people rely on maintaining the 

current status of the dunes.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 57 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 58 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Christophersen, Kell I know their heart is in the right place but it is time to get out 

of the box of policy, procedures and bias and move in the 

direction and focus of restoration, not closure.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 59 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Christophersen, Kell The first book end needs to starts with Alt 5 and end with 

open up all the 10C to 10B and get away from the silliness of 

closure to areas that are clearly non-native vegetation.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Christophersen, Kell Even on page 53 of the DEIS the Forest Service admits that all 

the 10C is non-native vegetation.

This statement is not correct. In the DEIS, Page 53

innumerates the number of acres of native vegetation within

reallocations from MA 10 (C) to MA 10 (B). No mention is

made in the table of the total acres of non-native vegetation in

all of MA 10 (C).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 60 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Christophersen, Kell Please stop the destruction of our ODNRA. Please, let’s all get 

together and rewrite the management to focus on 

Restoration, not closure.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Christophersen, Kell Of all the confusing language of the document this ‘High” 

rating of ‘Risk of introducing or spreading invasive species via 

the reallocation from MA 10C to MA 10B stands out as the 

most telling argument of the whole document. They are 

saying that they need to close 10C so we cannot ride in it 

because when we leave 10C the non-native vegetation there 

will attached to our tires and we will introduce non-native 

vegetation to 10B open sand thereby killing the open sand.

[...]We get confused just explaining it. One needs only to look 

at the maps and the pictures to know that the non-native 

vegetation spreads much faster in areas of the ONDRA that 

has been closed to OHV.

Please refer to FEIS, Chapter 3, Botanical Resources where it

states, "Non-native invasive plants are spread by wind, water,

animals, and people. one mechanism of plant spread is

vehicles that pick up sees and plant parts on their tires, body,

and chassis, transporting them to other locations where they

drop off and potentially start new infections. No specific

information was found that looks at the role OHV's may have

in the spread of invasive plants in the ODNRA. Else where, it

has been shown that vehicles do spread invasive plants, and

that potential to transport seed increases when the vehicle

travels off-road, and that the amount of seed that is carried by

the vehicle increases in wet conditions (MSU 2011). Because

sandy soils do not stick to vehicles in the same way as finer

loam or clay, the results of these studies may not be directly

appliciable to conditions in the project area, but some seed

transport by vehicles cannot be ruled out as well as the

potential to introduce seed from other areas outside of the

ODNRA where the vehicle may have been. The potential to

introduce or spread invasive plants by vehicle and what

degree of impact that has on other resources can be ranked.

Designating areas of largely native vegetation to open OHV

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 61 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

use would have the greatest risk of impact, followed by new

construction of designated routes through native vegetation

within Management Area 10 (C), designating an existing userdeveloped trail within native vegetation, and least impacting,

designating a user-developed trail through non-native

vegetation or opening an area of non-native vegetation to

open OHV use." It also states, "Intensive OHV use can reduce

or eliminate the colonization of invasive European beachgrass

and an argument could be made that reallocating areas from

Management Area 10 (C) to 10 (B) may provide some control

of this species. To be effective however, high frequency and

duration of use would need to be maintained over an entire

area. Because areas proposed for reallocation were selected

for their potential to provide trail riding opportunities, use

patterns would not likely result in any real reduction in

European beachgrass."

Christophersen, Kell Please start managing the 28,990 acres and quit closing the 

only economically viable way to kill the grass.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Cobb, Katherine It is beyond my understanding, therefore, that all private 

access to the dunes would be denied us.

The purpose and need for this project is to designate routes

are areas open to motorized used in Management Area 10

(C). The 1994 Dunes Plan directs that those routes will

connect open riding areas, or connect open riding areas to the

beach. Designating routes in MA 10 (C) that connect private

property to open riding areas does not comply with the

direction of the Dunes Plan.

Cobb, Katherine Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 62 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

We contribute to the economy of the area, as many 

landowners do- and it is/was the dunes that attracted us and 

keeps us coming back. There is such beauty and activity; but, 

without access and restricted riding, we are looking at an 

entirely different picture- one that I do not want to frame 

(and certainly won't hang on my wall!)! How- with such a 

severly depressed economy, with little-to-no industry -can this 

project be proposed to a recreational population that is one of 

the few income producing attractions in the area? We not only 

support the coast with

our love and maintenance of the land, but with our tax 

dollars, recreational spending, food,

entertainment, vehicle repair and homeowner expenses!!

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 63 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Cobb, Katherine Finally, what a loss for our children, who are the future of the 

dunes. I urge you to

use the funds that would be used to "police" the area to teach 

them, to train them, to

inform them and encourage them to love the dunes as 

something that is theirs to preserve

and prote4!t! Your dollars and mine would be much better 

spent! Too many are beginning

to see laws and restrictions as boundaries only to be broken! 

For once, can't we look

beyond restrictions and see possibilities?

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 64 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Cochran, Eric Losing any of the beautiful recreational sand dunes would 

mean not being able to re-live some of my favorite memories.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 65 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Cook, JC I'm hoping the land stays open. Thank you for your comment.

Cox, Leo The southern area near the beach of The Middle Dunes is a 

good example of proposed routes to be

closed that run primarily through beach grass. This area was 

just open sand less than 50 years ago according to the aerial 

photos that the FS has. During the "Rally at Riley" event that 

was held 11-17-12 conversations with Jerry lngersol revealed 

the FS didn't want to limit routes through beach grass and the 

route closures should not affect trails through beach grass. 

The proposed route closures show something different. In The 

Winchester Bay and Florance riding areas numerous routes 

near the Sea Wall would be closed that are mainly through 

beach grass. By closing these and other routes beach grass 

will soon take over the tralls and hasten the decrease of open 

dunes in the ODNRA.

The area of MA 10 (C) in the southwest portion of the Middle

Riding Area is proposed to be reallocated to open riding in

Alternatives 4, Modified 4 and 5.

Cox, Leo Another section of proposed route closures that would not 

encourage the ODNRA to "revert to a more natural condition" 

is the Northern Area of the North riding area of Florance. 

During the Dune Tour of the lOC Route Designation Project 

Working Group North Section, we toured an area t flat 

mushroom pickers use, FS personnel revealed this area was 

"man made" the trees were all planted to stabilize the shifting 

sands from crossing Hwy 101. The natural condition prior to 

planting trees was open sand dunes. The trees are all neatly 

planted in rows and are not 1'natural"' to this area. There are 

trails throughout this area and a small lake. This area was 

once open dunes it should be designated lOB open all the 

routes.

Please refer to FEIS, Chapter 2 Alternatives. Several

alternatives were analyzed in the FEIS, from No Action to

varying degrees of designated routes and rezoning

Management Area 10 (C) - Designated Routes only to

Management Area 10 (B) - Open. Alternatives 1, 2 and 3 do

not rezone any of the Shore Pine areas to Open

Riding. Alternatives 4 and Modified 4 rezone some of the area

to Open Riding (A10 - 33 acres) and Alternative 5 rezones

more (A12 -50 acres and A13 - 112 acres).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 66 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Cox, Leo The FS has a responsibility to manage the ODNRA with 

recreation in mind. Closing existing routes will decrease any 

positlve effect that OHV has on slowing down the 

encroachment of the beach grass. Routes will revert naturally 

to an unnatural state of invasive species domination. How can 

the FS allow this to happen?

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Cox, Leo I believe the best alternative would be to designate all of lOC 

into 108 open riding and encourage OHV use to be a 

deterrent to the spread of beach grass and other invasive 

species.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Coyne, Joe This letter is written in support of the least restrictive plan 

being offered and we would not object to a reconsideration of 

an additional alternative which would open up more area.

Thank you for your comment.

Coyne, Joe It would seem, and there have been statements made, that 

within 25 years the "sand dunes" will have many times the 

vegetation that it has now. Your plans should reflect this 

condition and make determinations that while nature does 

have a natural pattern which involves change, much of the 

reasons for the expected changes are manmade and work 

against the continued recreational use of the area with OHV.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Coyne, Joe Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 67 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Please recognize the recreational use of the sand by ATV and 

sandrail owners is one of the "industries" that economically 

supports our community and has a minimal adverse effect on 

the environment. As to the illogic of: because there has been 

no lessening of recreational

users to the area, our decisions have not been adverse to the 

economy. OHV users are growing at a fast rate, land available 

for such uses are decreasing. Without a " control site" your 

statement that there has not been an adverse impact is not 

supported.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 68 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

creighton, Eric I do not want the sand dunes shut down at all. This project does not proposing shutting down access to the

Oregon Dunes. The purpose of the project is to designate

routes and areas within Management Area 10 (C) as open to

OHV use.

Curtis, Bruce and Cathy If the Forest Service could find a way to leave things (routs) 

as they are now it will work for everyone.[...]Some of the 

changes being looked at will cause an over riding in the entry 

areas.

Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Davis, Laure Why was there no noise buffer allowed for the residential 

areas along Cleawox Lake? This problem needs to be resolved 

permanently.[...]One of the most glaring issues I see in the 

North riding area along the long arm of Cleawox Lake is the 

absence of a noise buffer zone.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Davis, Laure Whichever plan is chosen it must include enforceable decibel 

limits.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Davis, Laure Alternative number 5 is an invitation for problems. This 

particular plan brings the OHV rider right into the Cleawox 

Lake area that has many user developed trails that the plan 

proposes to close.

Action Alternatives 2, 3 4 and Modified 4 do not propose

reallocations to open riding near Cleawox Lake.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 69 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Davis, Laure This plan will; encourage riding on closed trails and the need 

for more man power for enforcement, anger residences who 

were anticipating increased quiet, increase dissatisfaction from 

non-motorized boaters who come to one of the most popular 

and scenic lakes for their quiet sport only to find obnoxious 

noise.

 

The Forest recognizes the need for upfront education and

enforcement of the designated routes decision to inform OHV

riders of routes open to motor vehicle use. Enforcement of the

trail system will be improved through signage, unauthorized

route closure, and regular patrols. Public compliance is

expected to increase with the formal designation of a more

understandable trail system connecting OHV riders to

beaches, open sand areas, and designated sand camps. 

No routes or areas are proposed for designation near

residential areas or areas of non-motorized recreation areas

incuding Cleawox Lake in order to lessen user conflicts and

the impact of noise from OHVs.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 70 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Davis, Laure Many people from all over the country come to Honeyman 

State Park for a vacation that does not include OHV riding. 

They come for the Lake and the beauty of the area – which 

includes serenity. Let the OHV rider have their, “highly valued 

recreational experience” somewhere that does not infringe on 

others who enjoy a quiet recreational experience. Alternative 

number 5 is a culmination of a lot of bad ideas designed only 

to serve the needs of one group.[...]We need to keep OHV 

riders in open sand areas, away from forested areas, wild 

animal habitat, residential areas, and other recreational areas 

where peace and quiet are cherished. There is plenty of room 

for OHV activity without being destructive or annoying to 

others. For all of the aforementioned reasons I endorse 

alternative number 2 as the most responsible choice.

Management of the ODNRA is guided by The Dunes Plan

(1994), which amended the Siuslaw National Forest Plan

(1990). A long-term goal of Dunes management is to "provide

a broad range of high-quality recreation settings and

opportunities..." (Dunes Plan, III-1). The Dunes Plan

established separate management areas with differing

resource emphases within the ODNRA. Non-motorized,

dispersed recreation is emphasized in MAs 10 (A), NonMotorized Undeveloped. Motorized use is emphasized in MA

10 (B), open riding; and MA 10 (C), OHVs permitted on

designated routes only. In other management areas,

recreation is not emphasized, but permitted in a manner that is

consistent with management objectives for the area. 

The Forest recognizes that user conflicts exist, but also

recognizes motorized recreation as a legitimate use of the

ODNRA. No routes or reallocations are proposed near areas

of non-motorized recreation or residential areas to reduce user

-conflicts while continuing to provide opportunities for

motorized recreation.

Davis, Laure Whichever plan is chosen it is only as valid as it can be 

enforced.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 71 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 72 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Dawson, Adele I support Alternative 4 and feel it is a fair compromise among 

all parties.

Thank you for your comment.

Dawson, Adele I would put the North boundary of A2 at Goose Pasture OHV 

Trail. This would help reduce the sight and sound of OHVs for 

non-OHV users. The nearby Dog Pond is a popular birding 

spot and can be irritatingly loud with OHV noise.

The northern portion of the proposed A2 reallocation would tie

into an existing designated route along the southern edge of

the South Jetty Road. OHV use of the designated route

accessing the beach from the Goose Pasture staging area will

continue just south, and visible from the South Jetty Road.

Dawson, Adele

I support all the reallocations proposed in Alternative 4 in the 

North riding area with the exception of a portion of A2.

The northern portion of the proposed A2 reallocation would tie

into an existing designated route along the southern edge of

the South Jetty Road. OHV use of the designated route

accessing the beach from the Goose Pasture staging area will

continue just south, and visible from the South Jetty Road.

Dawson, Adele I strongly oppose the proposed reallocations A12 and A13 in 

Alternative 5. This allows riders access temptingly close to 

Bear Lake (which has been savaged by riders in recent years) 

and the Cleowox Lake area . Residents in the area, swimmers 

and paddlers on the lake should not have to put up with OHV 

noise.

Thank you for your comment. Alternatives 1, 2, 3, 4 and

Modified 4 do not propose reallocations near either Bear or

Cleawox Lake.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 73 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dawson, Adele I feel that additional measures need to be taken regarding 

sound in the South Jetty area. The steep sand face near 

South Jetty staging area reflects the sound of fully revved 

engines racing up the hill back to the city of Florence. Where 

is the Noise Control Buffer for the city of Florence?[...]I feel 

that closing that steep sand face to riding would make a huge 

difference.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Dawson, Adele There are three sand camps, 28, 29 and 30 in the Incinerator 

OHV trail area that I feel need to be relocated.

Relocating sand camps is outside of the scope of this project.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA.

The designated sand camps along the Incinerator designated

route are popular sites that are occupied nearly every summer

weekend. The sites provide a sand camping experience that

has become popular with families with small children because

those sites are isolated from the traffic and activity occurring

on open dunes. User-developed routes in the Incinerator area

are proposed to be enforced as closed in all alternatives. 

Dawson, Adele User created trails have formed a web in the area directly 

adjoining the Lagoon Trail creating conflict with those trying 

to enjoy nature. In addition to the noise the area has been 

abused with litter and human waste.

No trails are proposed and no areas are proposed for

reallocation to open riding near the Lagoon Trail in any

alternatives in order to address user conflicts between nonmotorized recreation and motorized recreation in this area. 

Dawson, Adele I support Alternative 4 and the reallocation of Banshee Hill, 

A15.

I also support the reallocation of A16 as long as it allows 

riding only to the top of the foredune and is limited by a 

fence.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 74 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dawson, Adele I strongly support the closing of all other user created trails in 

the vegetated fingers of the Middle Riding Area to protect 

native habitats from further fragmentation and degradation.

Alternative 3 propose no OHV riding in the vegetated fingers

in the Middle Riding Area. Alternatives 2, 4, Modified 4 and 5

propose one reallocation to open riding of the area known as

"Banshee Hill."

DeFrees, Bryan I prefer alternative 5 because it opens up more trail riding 

areas.[...]I would hope that you would not close the userdeveloped routes.

The alternative of opening all user-developed routes is

discussed as an Alternative Considered but Eliminated from

Detailed Study.

DeFrees, Bryan Please consider the economic consequences of further 

reducing or closing off of areas. Plus, families come to the 

Florence area from canda, WA, & CA to enjoy this unique 

riding area.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 75 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

DeFrees, Bryan Please DO enforce noise limits. Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 76 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

DeMeyer, Chad The Forest Service needs to start from scratch to develop new 

alternatives that will provide maintenance of the OHV trailriding experience.[...]The Forest Service needs to start over in 

their assessment to develop new alternatives to provide 

reasonable solutions that will accommodate the user 

experience and protect the wetlands and vegetation, which 

may include opening more "open areas" to OHV use, or 

formulating a plan for the creation and maintenance of a 

designated trail system.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 77 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

DeMeyer, Chad The value of the trail riding experience is not found by wide 

connecting roads (i.e. whoop roads). The preferred alternative 

(4) closes 62% of trails (84 miles closed out of 135 miles) --- 

unacceptable.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 78 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

DeMeyer, Chad The trails connecting other open dunes areas are much 

needed in order to obtain access to other areas without 

having to transverse the whoop road’s or other high traffic 

area’s.[...]The trails in question have been around for 

decades, and while the 10c management plan calls for 

"controlled opportunities" for OHV use, the plan did not 

accommodate the growth of the various OHV users of the 

ODNRA.[...]Continually confining an ever growing recreational 

activity into a smaller and smaller area only leads to a 

diminished experience and several safety issues.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

DeMeyer, Chad The proposed actions are detrimental to the health of the 

sports and economy on the Oregon coast that rely on these 

areas, not to mention the safety and enjoyment of the clubs, 

people, and families that currently use the dunes for 

recreation.[...]Closing more of the dunes access will be 

signing away the futures of those small towns that are almost 

now entirely dependent on OHV and Dune access.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 79 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 80 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

DeWitt, Terry I strongly oppose any closing of the 10c areas that are 

created by non native plants.[...]All areas with non native 

plants need to remain open

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

DeWitt, Terry At a minimum the 10c boundaries need to be pushed back to 

the 1994 guidelines.

Current Managment Area 10 (C) boundaries are from the

1994 Dunes Plan. 

DeWitt, Terry areas like the fingers in the Winchester Bay area need to have 

the maps show that the trails around the edges are still open 

to riding.

Once a decision is implemented, maps will be made available

depicting areas that are open to and closed to motorized use.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 81 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

DeWitt, Terry there needs to be more open trails thru the wooded areas 

leading from one 10b area to the next. One or two connecting 

trails is not enough to handle all the traffic safely.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

DeWitt, Terry NO CLOSER OF ANY 10C AREAS SHOULD HAPPEN UNTIL THE 

NON NATIVE PLANT PROBLEM HAS BEEN ADDRESSED.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 82 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dexter, Forrest The land management under the proposed DEIS continues 

restricting OHV access rather than a

logical approach of vegetation enhancement and dune 

management with recreation management

as part of a coordinated strategy.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Dexter, Forrest Likewise to your area, we struggle in om area on forest 

revision plans which I understand is due for you next year.[...]

So it seems a cognizant dissonance for a current DEIS to be 

presented at

significant cost and effort when a well thought out revision 

plan next year should invalidate it and open the dunes back 

up to the public

At one time the Siuslaw national Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Dougherty, Brandon & Haylie Many of the trail between Horsfal Dunes and the ocean are 

fun winding trails that we love to take the younger kids on 

because they are safer and easier to ride then the tall peak 

dunes in the middle. Second closing many of the side trail and 

winding trails through the trees and grass will cause 

congestion in the middle open dune area. This increases the 

risk of collisions, injury and overall amout of traffic through 

the middle dune area.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 83 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dougherty, Brandon & Haylie By limiting the area that many of these ATV enthusiast love to 

ride you'll be creating a huge loss in revenue.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 84 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Dougherty, Brandon & Haylie This is public land and any and all Americans should have the 

right to enjoy it. Shut these areas down is not the answer.

The Forest Service is not proposing to shut down the Oregon

Dunes National Recreation (ODNRA) nor prevent use of the

area by the public. The purpose and need for this project is to

complete the designation and development of a

comprehensive, understandable designated OHV route

system within the MA 10 (C) areas of the ODNRA. MA 10 (C)

areas consist of 15% of the ODNRA, or about 4,455 acres.

Drake, Randell more motorized user needs to equate to more

acreages are needed for OHV use.[...]Build the trails as drawn 

in Alternatives 4-5 working with the OHV groups and things

will change accordingly. There is no need to close anything 

but there is a need to leave

open and open more areas up for OHV use.[...]We the OHV 

communities are asking

you and have been asking you to just set the outside 

boundaries. This cannot be done and

should not be done on the eastward side unless it is private 

property.[...]more user equates to

more public land is needed for motorized use and do not close 

any portion of the dunes

(leading edge is part of the active dunes) or the trails within. 

Any closures in this OHV area

will diminish our sand dune experience within the Siuslaw 

National Forest public lands.[...]We ask you; the managers of 

these land to

work just as hard in keeping all of this area open and to 

No new construction of OHV trails is proposed. Areas have

been proposed for reallocation to MA 10 (B) open riding from

their current designation of MA 10 (C), open to OHVs on

designated routes only in Alternatives 2, 4 Modiified 4 and 5.

Opening areas currently managed as closed to OHV use is

outside the scope of this project.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 85 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

expand it to us as well.[...]We will support you in your efforts 

in signing of existing, blending of old and new trails into

a trail system as Alternatives' 4-5 spell out. We will support 

your efforts in keeping open

the new and old open riding areas. We will support the 

opening of as many acres of the new

dunes within the lands of Siuslaw National Forest as possible. 

We do not support you in any

efforts to close any dunes or motorized user created trails 

within the Siuslaw National

Forest. We believe there are no unauthorized riding areas or 

trails within this set aside

area particularly for OHVs that need closed.[...]We ask you to 

allow as many as possible to recreate

in a motorized vehicle as all your land can hold.[...]Closures 

are not land management especially when the land manager 

can plainly see more

land is needed.

Drake, Randell The Siuslaw National Forest needs to take a hard look at the 

issues from the OHV

communities as presented and not solely by those presented 

by the anti-access

environmentalists which have a goal and that is to remove all 

motorized actives from

public lands.[...]The alternative presented by Siuslaw National 

Forest does not express the OHV community

Comments both Oral and written.

The Forest followed laws, policies and regulations in soliciting

input for this project. The Siuslaw National Forest began

seeking information from the public in regard to the

Designated Routes project in 2009, when the Forest hired an

independent contractor to assemble and facilitate a working

group of individuals with varied interests in the Oregon Dunes.

In 2010, this working group provided ideas regarding a system

of designated trails and open riding areas that they believed

would meet the 1994 Dunes Plan. The results of their work

was posted to the Forest website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 86 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 130 comments on the DEIS.

Duckworth, Clint I would strongly urge that before you close land you first look 

at the land in question and take it back to its natural state 

before closing it of to the public.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 87 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Duckworth, Clint All closing down area will do is put more people in a smaller 

area and allow the non indigenous plants to take over the 

dunes.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Dunbar, Rick It has come to my attention that there is a draft proposal to 

close nearly 62% of the trails in the Oregon Dunes NRA.

The preferred alternative in the DEIS would enforce

approximately 62% of user-developed routes within the 4,455

acres of Managment Area 10 (C) as closed.

Dunbar, Rick I wanted to strongly urge those in charge of this project to 

carefully consider what their decisions would do not only to 

the recreation opportunities for the hundreds of thousands 

that visit the ODNRA every year, but also to the local economy 

of the Coos Bay/Reedsport/Florence communities.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 88 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Dutra, Kayla Cutting down the riding area will make it even smaller than it 

already is and seeing how it has already been cut almost in 

half since the first time that I rode there seems not only 

unethical and ridiculously unsafe but unfair to the people who 

enjoy this kind of sport.[...]this would cause way more 

accidents and make it over crowded.[...]Not only would this 

be a hardship for the people that enjoy and live for this kind 

of sport but will have an extreme impact financially for the 

towns and businesses in that area.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 89 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eads, Gary Regarding the changes to the riding areas I have to disagree 

with the “new” restrictions[...]We camp, spend money, eat in 

restaurants, not only in the coastal area but in Elkton and 

Sutherlin on the way.[...]The trails behind the beaches are fun 

and gentle, not everyone likes to ride the climbs and drops of 

the open dunes[...]Eliminating many of these trails will cause 

heavy use of the remaining trails and may lead to more 

collisions by concentrating the riders into a smaller area[...]

why would you take away one of the leading if not the largest 

source of revenue to the Oregon Coast.

Econimic impacts, trail riding and safety are addressed in

response numbers 13, 71 and and 17 respectively.

Eatherington, Francis The Forest Service should begin efforts toward ecological 

restoration of the Dunes, also called for in the 1994 Dunes 

Plan.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 90 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis The Forest Service should not revise the Dunes Plan to 

expand the open riding areas.

A fundamental purpose of the 10 (C) designation in the Dunes

Plan is to restrict cross-country OHV use to protect native

vegetation. However, parts of MA 10 (C) are in fact dominated

by invasive species such as European beachgrass and Scots

broom. In part, this reflects mapping errors that date back to

the original aerial photo interpretation and vegetation typing

done for the 1994 Dunes Plan. Some areas allocated as MA

10 (C) were subsequently found on the ground to better meet

the appearance, conditions and management objectives of MA

10 (B). Non-native, invasive species do not need protection

from impacts by OHVs. Re-zoning these areas from 10 (C) to

open riding promotes user understanding and acceptance of

restrictions that are actually needed and may further

objectives for restoration of open sand.

Eatherington, Francis The Forest Service needs to make a commitment to 

implement the decision and inform OHV riders of designated 

routes with clear signage, wildlife-friendly fencing, and active 

enforcement.[...]The Forest Service should now make a 

commitment to having clear, enforceable standards that are 

understood by the general public.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 91 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 92 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Eatherington, Francis Drop the A16 open riding area in order to protect Tenmile 

Research Natural Area (RNA) and Snowy Plover habitat.[...]In 

the Middle Riding area, A16 designates a big block (132 acres) 

of vegetation being moved from 10C to 10B, along the stateowned nonmotorized beaches, and just north of the Tenmile 

Research Natural Area (RNA) and Snowy Plover Habitat. There 

are user-created trails that currently go through the A16 

proposal, right into these sensitive areas. Designating A16 to 

be 10B could increase these incursions onto the nonmotorized beaches, into the RNA and Snowy Plover Critical 

Habitat. The DEIS failed to describe these existing usercreated trails and how they would be blocked after the area 

immediately north of them has increased traffic from 

designating it 10B.[...]A16 is also 25% in native habitat (Table 

24).[...]The DEIS finds (page 81) that invasive species have 

the potential to establish along these existing trails and any 

that are newly created in the future. The Sickle-leaved rushSalt rush association occurs in a small area in the southwest 

corner of A16. Currently, there are no user-developed trails.

[...]A16 should be eliminated to protect the Sickle-leaved rush

-Salt rush plant association.

The boundary line separating the Umpqua riding area and the

Tenmile Research Natural Area (RNA) is posted as closed to

OHVs with signs on wooden posts. During field observations

over that last eight years, this line of staggered signing

through the open sand of MA 10 (B) has been an effective

deterrent to OHVs. The only user-created route entering the

RNA from the area south of A16 has been barricaded at the

Coos/Douglas County line and has been monitored for the

past four years.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 93 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis Area A14 should be dropped to protect predominantly native 

vegetation.[...]A14 is proposed in 96% native habitat (DEIS 

Table 24). This is unacceptable and must not be reallocated.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Eatherington, Francis Native vegetation and wetlands should be protected from 

motorized recreation.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Eatherington, Francis Trail riding can instead be accomplished with a few of the 

proposed designated trails instead of reallocating hundreds of 

acres to cross-country travel.

Please refer to Response #72 for a discussion of the

distinction between trail riding, and traveling on designated

routes.

Eatherington, Francis the EIS failed to clearly delineate where the sensitive or 

globally significant vegetation is within, or adjacent to, the 

areas proposed for reallocation.[...]Table 24, page 72, 

quantified the native vegetation present within the areas 

proposed by the conversion from 10C to 10B. What table 24 

did not disclose is how much of the native vegetation remains 

still protected elsewhere, and how protected is it. For 

instance, 7% of the A5 reallocation is Slough sedge.[...]Is this 

50% or 100% of the entire Slough sedge plant association in 

the area? What percentage of slough sedge is adjacent to 

newly created 10B and how much is truly protected?

This has been corrected in the FEIS, Chapter 3, Botanical

Resources. The delineated maps are included in the

Botanical Resources Specialist report.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 94 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis The DEIS failed to describe the existing condition, such as 

how wide user-created trails

are now. The DEIS also failed to describe how wide the trails 

would become if they become a designated route. We 

understand from conversations with the Forest Service that 

existing user-created trails average about 12325 wide, and 

the trails that become designated routes could be expanded 

up to 16 wide.11 These details should have been in the DEIS.

Many routes proposed for designation are currently 16 feet

wide. All proposed designated routes would be managed in

their current condition, and not be mechanically widened to 16

feet, with one exception. R16 would be widened to 16 feet in

order to accomodate two traffic entering the beach. This route

would accomodate traffic that currently uses the Breach route

to access the beach. The Breach route is proposed to be

closed seasonally to protect Snowy Plover winter habitat. 

Eatherington, Francis The FEIS should be clear on how wide the new trails are, how 

wide they can become, and what is allowed within that width 

if part of it is vegetated.

Please refer to Response #191.

Eatherington, Francis The DEIS failed to explain if highway-legal vehicles, such as 

pick-up trucks, SUVs and Subarus, would be allowed on the 

newly designated trails, or if just non-highway-legal OHVs use 

would be allowed. (See 322Roadless Rule discussion below for 

more on this).

OHVs are vehicles capable off road travel.

Eatherington, Francis The Siuslaw TMP EA says: Non-highway-legal OHV use would 

be allowed on all Siuslaw NFS roads open or closed, unless 

roads are paved or wider than 1.5 lanes. It is our 

understanding the newly designated routes will be two-lanes, 

wider than 1.5 lanes.

Designated routes are not roads, and are therefore not

managed as roads. Designated routes within the ODNRA are

considered part of the Nation Forest trail system. All

designated routes will be maintained to comply with the design

criteria found in Forest Service Handbook 2309.18, Chapter

20 as funding allows. Designated routes will meet 23.23

Exhibit 01-Design Parameters for Trail Class 2 (DEIS, FEIS, p.

48).

Eatherington, Francis The FEIS should confirm which of the newly designated routes 

will be managed as 16-wide 2-lane routes.

Many routes proposed for designation are currently 16 feet

wide. All proposed designated routes would be managed in

their current condition, and not be mechanically widened to 16

feet, with one exception. R16 would be widened to 16 feet in

order to accomodate two traffic entering the beach. This route

would accomodate traffic that currently uses the Breach route

to access the beach. The Breach route is proposed to be

closed seasonally to protect Snowy Plover winter habitat. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 95 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis The DEIS failed to describe if the newly designated 12-wide 

trails would be widened to 16, and if so, how and when that 

would occur.

Many routes proposed for designation are currently 16 feet

wide. All proposed designated routes would be managed in

their current condition, and not be mechanically widened to 16

feet, with one exception. R16 would be widened to 16 feet in

order to accomodate two traffic entering the beach. This route

would accomodate traffic that currently uses the Breach route

to access the beach. The Breach route is proposed to be

closed seasonally to protect Snowy Plover winter habitat. 

Eatherington, Francis The DEIS says, page 50, under the heading of Soil Resources, 

that: Clearing vegetation for designated route 

construction/maintenance will be conducted during 1 June-15 

September. Minimize total removal of existing vegetation by 

trimming to a height that allows users to proceed but does 

not kill/remove the vegetation unless removal is required for 

OHV route width standards. The FEIS should make clear how 

many of the trails would be cleared in this manner, vs how 

many miles would be cleared by users, or not cleared at all. 

For the trails that would

be widened as they are being used, how will the Forest 

Service stop that clearing at 16?

Many routes proposed for designation are currently 16 feet

wide. All proposed designated routes would be managed in

their current condition, and not be mechanically widened to 16

feet, with one exception. R16 would be widened to 16 feet in

order to accomodate two traffic entering the beach. This route

would accomodate traffic that currently uses the Breach route

to access the beach. The Breach route is proposed to be

closed seasonally to protect Snowy Plover winter habitat. 

Eatherington, Francis The FEIS should be clearer on the intention of the Forest 

Service to do restoration work, or not, on user-created trails 

not designated as authorized routes in 10C.

Trails not designated will be obliterated or allowed to revert

naturally. In response to comments asking for more

information, we have included more specifics in the Project

Design Criteria of the FEIS. Closures are also addressed in

the Wildlife Biological Assessment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 96 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis It is also glaring that the FS is only addressing restoration of 

unauthorized trails in 10C and not in any other land allocation. 

There are 135 miles of unauthorized trails in 10C

and perhaps thousands of miles in other areas, such as in 10E 

-- Snowy Plover Habitat,

10F -- Plant, Fish and Wildlife Habitat, 10G - Wetland 

Management, 10H - Plant, Fish

& Wildlife Viewing, and 10J - Wild and Scenic River.

Addressing trails in management areas other than MA 10 (C)

is outside of the scope of this project. The purpose and need

for this project is to complete the designation and

development of a comprehensive, understandable designated

OHV route system within the MA 10 (C) areas of the

ODNRA. Restoration of user created routes in other

management areas is outside the scope of this project.

Eatherington, Francis The FEIS should explain, if restoring an unauthorized trail in 

10C, will the restoration just stop at the 10C border, and not 

address the rest of the trail as it crosses into 10H or 10F?

Trails not designated will be obliterated or allowed to revert

naturally. In response to comments asking for more

information, we have included more specifics in the Project

Design Criteria of the FEIS. Closures are also addressed in

the Wildlife Biological Assessment.

Eatherington, Francis the DEIS failed to map the miles of user-created trails in land 

allocations other an 10C.

Restoration of user created routes in other management areas

other than MA 10 (C) is outside of the scope of this project.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA.

Eatherington, Francis The FEIS must explain why non-10C protected vegetation is 

not receiving the same protections from unauthorized 

motorized use as 10C.

All areas closed to OHV travel are protected in the same

fashion. The policy is to use the three E's; Education,

Engineering and Enforcement. Education is includes maps

and staff contacts. Engineering includes assurance signing,

fencing, and barricades. Enforcement is described in the

FEIS, Chapter 3, Law Enforcement.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 97 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis remaining native vegetation on the federal ownership be 

protected and restored. The

reallocation of A4 and A5 in the south riding area should be 

eliminated in all alternatives.[...]Table 24 documents one of 

the globally significant communities, Shore Pine/ Slough 

Sedge that is within the A4 reallocations. Additionally, Slough 

Sedge is within the A1, A14, A16, and A5 (A5 is adjacent to 

the 10F allocation north of Beale Lake). Further motorized 

impacts to these areas should not be allowed.

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Eatherington, Francis Maintain and protect the 10F designation at Beale Lake.[...]

The DEIS failed to mention this important place, failed to map 

existing illegal trails, and

failed to consider the impacts of changing the adjacent area 

to open riding. The DEIS

should have described how the 10F area would be fully 

protected in the face of this added

threat of increased OHV use.[...]A5 should be eliminated.[...]

Since a 10B designation will bring more

riders to this area, the Forest Service must move the no-riding 

signs up to the boundary of the 10F designation around the 

entire lake.[...]If clear no-riding signs are not posted around 

the boundary of 10F (as opposed to Beale Lake), and around 

all sensitive vegetation, designation of the adjacent areas to 

10B will elicit an appeal of the decision.

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 98 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis The DEIS says that A4 South is being moved from 10C to 10B 

to provide access from the Horsfall campground and staging 

area to open sand (DEIS page 46). This doesn't make sense. 

Horsfall Campground and the staging area already have 

access to open sand via a designated trail (identified as trail 

1343 on the motor vehicle use map). Converting A4 would 

only get them to open sand a few minutes sooner. If that time 

is important, then designate new trails R14 and R15.

A4 (south) would provide direct open sand access from the

Horsfall staging area. Accessing open sand via designated

1343 is indirect and impassable for vehicles pulling trailers

due to several large dunes between the area where 1343

enters open sand and the area of open sand approximately

100 yards from the Horsfall staging area.

Eatherington, Francis A4 South and A4 North are being proposed near Horsfall Lake 

to be moved from 10C to 10B in alternative 2, 4, and 5. We 

encourage the Forest Service to choose the alternative 3 

option for this area instead, designating new trails R14 and 

R15 instead of A4.[...]Choose Alternative 3 around Horsfall 

Lake.[...]Concerning trails R10, R12, and R13 in Alternative 4 

and 5: The DEIS failed to show these are necessary since the 

Hauser OHV trail already connects riders to open sand areas. 

If they are simply to increase trail riding experiences, then the 

DEIS should have said that instead of claiming they are 

needed to connected open riding areas. They are especially 

problematic since

they are 3 out of the 4 trails that are adjacent to vegetation 

communities that are predominately native R10 and R12 have 

problems from water on the trail and the potential of the trail 

widening from users avoiding the water. R13 has slope 

stability issues. These user-created trails should be 

rehabilitated, not expanded by designating them.

Routes proposed for designation in the Hauser area,

including R10, R12 and R13 would alleviate congestion and

provide additional routes for travel from the open riding area to

the beach, as described on pages 45 and 46 of the DEIS and

FEIS. Routes are designated in MA 10 (C), as directed by the

Dunes Plan, to protect vegetated habitats and are therefore

not precluded from designation due to the existence of native

vegetation. 

Please refer to "Issues" in Chapter 1 of the DEIS and FEIS for

a discussion of the differentiation between the trail riding

experience and the experience of traveling on designated

routes.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 99 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis The DEIS (page 46) says A4 North (alt 5 only) is needed for 

access to designated sand camp numbers 7 and 8. We could 

not find these sand camps identified on any maps with sand 

camp numbers. Again, is not access provided by trail 1342? 

Designation A4 North would simply provide an ATV play area 

immediately around the sand camps. Access to open sand is 

already provided

A4 (south) would provide direct open sand access from the

Horsfall staging area. Accessing open sand via designated

1343 is indirect and impassable for vehicles pulling trailers

due to several large dunes between the area where 1343

enters open sand and the area of open sand approximately

100 yards from the Horsfall staging area.

Eatherington, Francis The DEIS failed to clearly show that unique vegetation would 

not be threatened with A4 reallocations near Horsfall Lake. 

For instance, Plant Associations of the Oregon Dunes18 

describes (page 12) the 300-400 year-old stands of Port 

Orford cedar near Hauser and in the Horsfall area. It also says 

(page 13), that 120-150 year old 322old-growth shore pine 

occurs on tree islands in the Horsfall area. The DEIS failed to 

confirm these stands would be fully protected, even if they 

were outside of the A4 boundaries.

The FEIS, Chapter 3, Botantical Resources Section describes

the vegetation located within the the A4 reallocation. Areas

adjacent to the reallocation, as with all areas that are not open

riding will be monitored. Please refer to FEIS, Chapter 3, Law

Enforcement Section regarding law enforcement

contact. Also, please refer to FEIS, Chapter 2, Project Design

Criteria which discusses techniques for closing user created

routes. Specifically, a Botany Project Design Criteria

state: "Employ barriers or other methods to discourage offtrail OHV use in areas of native vegetation susceptible to OHV

impact." (FEIS, p. 62)

Eatherington, Francis the DEIS failed to show that new riding areas (A4 and A5) in 

the southern riding area would not damage the unique 

qualities of Beale and Horsfall Lakes themselves.

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 100 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis Currently, on Google Earth, it is possible to see several usercreated trails that go into the

Tenmile Research Natural Area. The DEIS failed to map these 

or consider how designating the adjacent area north of there, 

where these trails originate, as 10B, will solve, or enhance this 

problem. A better solution to providing increased trail riding 

and access to walking on the beach is the Alternative 2 and 3 

R8 designated trail. However, even R8 has problems as it is 

along native vegetation, and 322invasive species311 could be 

expected to colonize areas along routes, potentially spreading 

from the trail and impacting nearby vegetation.

The boundary line separating the Umpqua riding area and the

Tenmile Research Natural Area (RNA) is posted as closed to

OHVs with signs on wooden posts. During field observations

over that last eight years, this line of staggered signing

through the open sand of MA 10 (B) has been an effective

deterrent to OHVs. The only user-created route entering the

RNA from the area south of A16 has been barricaded at the

Coos/Douglas County line and has been monitored for the

past four years.

Eatherington, Francis Concerning A15, Banshee Hill, we agree, it makes sense to 

reallocate that area from 10C to 10B.

Thank you for your comment.

Eatherington, Francis There appears to be an error in the DEIS when describing A12 

and A13. In Alternative 5, A12 and A13 on the map look 

almost identical in size, or A12 is slightly larger. Yet Table 21 

(EIS page 47) tells us A13 is twice as large as A12. Something 

doesn't make sense. Either the map, or Table 21 is wrong.

Sand camp numbers will be corrected in the FEIS, and maps

will include all designated sand camps. For further discussion

on A4 please refer to Response #142.

Eatherington, Francis To add to confusion, the Alternative 5 DEIS map of the North 

Riding Area calls this area

A12 instead of A7.

Thank you for this correction. A7 is not placed correctly on the

map and will be corrected in the FEIS. The rationale for A7

can be found in Table 26 of the FEIS.

Eatherington, Francis Assuming the number A7 is misplaced on Map 4, and should 

be placed in the area bordered by R3 and the South Jetty A 

OHV Trail, we fail to see the need for this reallocation along 

with two designated trails. It's overkill, especially since the 

area has been identified in the EIS as problematic for fish and 

soils.

Thank you for this correction. A7 is not placed correctly on the

map and will be corrected in the FEIS. The rationale for A7

can be found in Table 26 of the FEIS.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 101 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis Reallocating some smaller areas, such as A6, A8, and A9, to 

10B appears to have minor impacts since these areas have 

extensive user-created trails already into the 10C area. 

However, turning these areas into 10B could endanger the 

remaining 10C, as incursions will always happen on the edges 

of 10B. Legalizing these unauthorized trails could have the 

impact of creeping user-created trails further into the heart of 

the 10C protected vegetation.[...]Likewise, areas with uneven, 

difficult to map, or difficult to sign edges, like A1, should not 

be reallocated to 10B. Because the Forest Service already has 

difficulty enforcing 10C boundaries, areas like A1 would be 

impossible to enforce and only encourage creeping incursions 

further into 10C.

Areas of MA 10 (C) that are not designated routes have not

been enforced as closed in the past. With the implementation

of this plan, closures will be supported through education,

engineering and enforcement. Reallocations were proposed to

meet the purpose and need for this project which, in part, is to

complete a comprehensive, understandable designated OHV

route system that can be effectively managed and maintained

( FEIS, p. 11). 

Eatherington, Francis The solution to this problem is to either

designate a trail to Sand Camp 14, or move the camp north to 

the open sand. Moving

Sand Camp 14 north to the existing 10B area would be a 

minor change that could be done

in the FEIS.

The rationale for reallocating A1 is described on page 57 of

the FEIS. This reallocation would not only provide access to

Sand Camp 14, but it would also provide a trail riding

experience through predominantly non-native vegetation

including scotch broom and European beachgrass, while also

connecting open riding areas.

Eatherington, Francis A2 provides trail-riding fun on the foredune next to the beach. 

However, the DEIS failed

to discuss if that was a non-motorized beach. If so, 

reallocating the foredune to cross-country motorized traffic 

will only increase traffic on a non-motorized beach. This is

especially problematic since a Snowy Plover critical habitat is 

just south of A2, separated only by web of illegal, usercreated trails in 10C.

The beach along the entire length of the North Riding Area is

open to motorized vehicles year-round and under the

jurisdiction of Oregon Parks and Recreation.

Eatherington, Francis Without increased law enforcement,

increased incursion into important non-motorized areas will 

occur when the adjoining

area is reallocated to 10B.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 102 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 103 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 104 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis this foredune should be rehabilitated to expand

protected beach and plover habitat.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Eatherington, Francis The DEIS failed to explain a need for R3 The Rationale for R3 can be found in the Table 26 of the

FEIS.

Eatherington, Francis The EIS also failed to describe the need to designate the area 

near R3 as 10B. The DEIS

is unclear what number this is, perhaps A7? The Alternative 4 

map has A7 over a 10C area not proposed to be changed to 

10B, so perhaps the proposed change north of there is

called A7, though it is labeled as A12 on the Alternative 5 

map.

Thank you for this correction. A7 is not placed correctly on the

map and will be corrected in the FEIS. The rationale for A7

can be found in Table 26 of the FEIS.

Eatherington, Francis Alternative 5 in the Northern riding area designates A14, 

converting it from 10C to 10B. It also designates A2 from 10C 

to 10B. This leaves a narrow strip of 10C between A2 and 

A14. This will also be difficult to enforce.

The area between A14 and A2 is a thickly vegetated deflation

plain that is underwater most of the year. It has very few userdeveloped routes because it is largely inaccessible by

motorized vehicles. These factors will aid in enforcing userdeveloped routes between the proposed reallocations of A14

and A2 as closed.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 105 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis A survey for threatened, endangered, and sensitive (TES) 

vascular plants, mosses, liverworts, and lichens was 

conducted between February and September, 2011. Based on 

documented sites in the area (USDA NRIS 2010) and the 

potential to find suitable habitat within the project area, the 

survey targeted 14 vascular plant, 2 moss, and 10 lichen 

species. The effect of all alternatives on TES botanical species 

is no impact and further discussion is not needed.

The DEIS failed to disclose the list of targeted species or the 

results of the surveys. The DEIS also failed to describe where 

the surveys were done. Surveys should have been done in at 

least 3 kinds of areas: 1) areas with potential significant 

modification, such as

vegetated areas that could be reallocated from 10C to 10B, 2) 

vegetated parts of the usercreated trails that would be authorized, and 3) sensitive areas 

adjoining these new riding

areas as they are under increased pressure from new 

incursions.

 

The survey was conducted on the entire project area. The

botany report (2012a) stated, "The majority of the project area

(52%) was found to be in plant community types associated

with deflation plain habitat. The most dominant was the

Hooker willow/Slough sedge-Pacific silverweed (Salix

hookeriana/Carex obnupta-Argentina egedii) shrubland

association (Christyet al. 1998).Non-native communities

dominated by European beachgrass (Ammophila arenaria)

and Scots’s broom (Cytisus scoparius) with planted or

colonizing shore pine (Pinus contorta var contorta) was found

in forty-one percent of the project area, particularly in foredune

areas and adjacent to Management Area 10(B) where OHV

use patterns generally favor non-native vegetation. Natural

forest vegetation, originating before dune stabilization began

in the 1950’s, occurs in small stands and totals three percent

of the vegetated communities in the project area. The

remaining four percent is predominately native upland

meadow type vegetation. The most limited vegetative

community found was dune sedge (Carex pansa), a lowgrowing native dune plant found on stabilized well-drained

sand." The list of targeted species was omitted from the DEIS,

but can be found in the FEIS, Chapter 3, Botanical Resources

Section, Table 25.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 106 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis The Forest Service failed to do Survey and Manage surveys of 

the Northwest Forest Plan. Designating miles of partially 

vegetated areas for routes and designating vegetated

blocks for cross-country OHV travel is a ground disturbing 

activity.[...]Several of the 10C to 10B reallocations are along 

the coast. Plant Associations of the Oregon Dunes describes 

(page 12) a high incidence of rare lichen species along the 

immediate cost in tree islands. This should trigger Survey and 

Manage surveys. Species on the S&M list have suitable habitat 

in the Dunes, occur within the project area, and are closely 

associated with late successional forest.[...]

In the recent Riley Ranch project that designated a new trail 

through 10C, surveys adjacent to an existing trail revealed a 

rare lichen, Erioderma sorediatum, a species on the Survey 

and Manage list. The Forest Service should have determined 

what other species could be present by doing S&M surveys

Survey and Manage information was omitted from the

DEIS. That information is included in the FEIS, Chapter 3,

Botanical Resources Section and Wildlife Section.

Eatherington, Francis Table 24, page 72 fails to describe which lichen and fungi are 

within the proposed reallocations. Research indicates that the 

lichen layer could take more than 8 years to recover from 

trampling.

Survey and Manage information was omitted from the

DEIS. That information is included in the FEIS, Chapter 3,

Botanical Resources Section and Wildlife Section.

Eatherington, Francis The Oregon Dunes plan says that Additional globally 

significant communities may be added to MA 10(F) as they 

are discovered.323 Were any discovered in the most recent 

surveys?

No additional communities were discovered.

Eatherington, Francis The DEIS, page 56, says: 322Despite direction dating back to 

the original Dunes Plan

(1979), user-developed routes have never been effectively 

closed or enforced at the

ODNRA.323. The DEIS doe not describe how this existing, lack 

of enforcement would change, or not, with any of the 

alternatives.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 107 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 108 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Eatherington, Francis The DEIS failed to identify which proposed areas and routes 

would be located within

inventoried roadless areas (IRAs).

The DEIS says, page 136: “The 2001 Roadless Rule does not 

apply, because the Rule

only prohibits the construction and reconstruction of roads”...

We disagree. The Roadless Rule does apply because the 

Forest Service is proposing to

designate 2-lane, 16’ wide roads that will accommodate street

-legal vehicles, including

pick-up trucks, SUVs, Subaru’s, 4x4’s, AWDs, and any vehicle 

that can drive on the

designated routes. This meets the definition of “roads”.

The 2001 Roadless Rule does not apply to this project. 

From the Federal Register:

Comment on ‘‘Road’’ Definition. Respondents expressed

concern that the definition of a road was ambiguous and failed

to recognize the primitive travelways used by motorized

recreationists. Some respondents were concerned that the

definition indicated permission for the construction of a

travelway over 50 inches wide for offroad vehicles if the road

was determined to be a trail. Other respondents thought that

the definition of classified roads should include

Revised statute (R.S.) 2477 roads. 

Response. For agency consistency, this final rule includes the

same definitions of ‘‘road,’’ ‘‘classified road,’’ ‘‘unclassified

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 109 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

road,’’ and ‘‘temporary road’’ that are contained in the National

Forest System Road Management regulations (36 CFR part

212) and policy (Forest Service Manual 7700 and 7710)

transmitted on January 4, 2001 for publication in the Federal

Register. Based on consideration of public comment received

on the road management proposal, these definitions

were revised for clarity and a definition for ‘‘temporary road’’

was added. A trail is established for travel by foot, stock, or

trail vehicle, and can be over, or under, 50 inches wide.

Nothing in this paragraph as proposed was intended to

prohibit the authorized construction, reconstruction, or

maintenance of motorized or nonmotorized trails that are

classified and managed as trails pursuant to existing statutory

and regulatory authority and agency direction (FSM 2350).

Nor was anything in this paragraph intended to condone or

authorize the use of user created or unauthorized roads or

trails. These decisions are made subject to existing agency

regulations and policy and that intent has been retained in the

final rule.

Future claims and existing rights for R.S. 2477 roads would

not be affected by this rule. The agency recognizes valid R.S.

2477 rights-of-way. However, the validity of R.S. 2477

assertions must be evaluated on a case-by-case basis.

Therefore, there is no need to modify the definition of

classified road for this purpose. (FR, January 12, 2001. Page

3251)

The definition of a road is:

36CFR294.11 Road. A motor vehicle travelway over 50 inches

wide, unless designated and managed as a trail.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 110 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

We are managing these travelways as motorized trails.

Eatherington, Francis no cumulative impact analysis of this project on the inholdings 

of nonfederal lands within the dunes. Most of the non-federal lands 

allow OHV access, crosscountry riding and trail riding. Many of the designated trails, 

as well as user-created

trails, start or stop on non-federal lands. Many of the usercreated trails in 10C are

accessed by non-federal lands, such as the area around 

Horsfall Lake and Spirit Lake.

The impacts of motorized recreation on non-federal lands 

would add to the impacts of

motorized recreation on the NRA.

 

Cumulative impacts were considered.

40 CFR – 1508.7 CEQ – Regulations for Implementing NEPA

defines Cumulative (effects) impact as "Cumulative impact" is

the impact on the environment which results from the

incremental impact of the action when added to other past,

present, and reasonably foreseeable future actions regardless

of what agency (Federal or non-Federal) or person undertakes

such other actions. Cumulative impacts can result from

individually minor but collectively significant actions taking

place over a period of time.

The June 24, 2005 letter from CEQ regarding Guidance on the

Consideration of Past Actions in Cumulative Effects Analysis

stated, “The analysis of cumulative effects begins with

consideration of the direct and indirect effects on the

environment that are expected or likely to result from the

alternative proposals for agency action. Agencies then look for

present effects of past actions that are, in the judgment of the

agency, relevant and useful because they have a significant

cause-and-effect relationship with the direct and indirect

effects of the proposal for agency action and its alternatives. 

CEQ regulations do not require the consideration of the

individual effects of all past actions to determine the present

effects of past actions. Once the agency has identified those

present effects of past actions that warrant consideration, the

agency assesses the extent that the effects of the proposal for

agency action or its alternatives will add to, modify, or mitigate

those effects. The final analysis documents an agency

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 111 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

assessment of the cumulative effects of the actions

considered (including past, present, and reasonably

foreseeable future actions) on the affected environment.”

The FEIS considered the past actions from the planting of

invasive species to the number of undesignated trails within

Management Area 10C in Chapter 3, Environmental

Consequences. Understanding that there is the potential for

OHV riders to ride where it is not designated (off designated

routes in Management Area 10C or trespassing on private

property) the Forest plans on utilizing the three E’s, Education,

Engineering and Enforcement. The first step is Education

which would utilize maps and staff contacts. Engineering

includes such things as assurance markers, fencing and

signage. Enforcement would be used as described in the

FEIS. However, since it is not known where or how much

OHV riders may ride where it is not designated or where

trespass may occur, it is not possible to quantify the specific

environmental effects of these actions in a cumulative effects

analysis.

Eatherington, Francis Likewise, some non-federal landowners have problems with 

unwanted motorized

recreation impacts on their properties, including trespassing, 

noise disturbance and

noxious weed dispersal. The DEIS failed to consider the 

impact of this action on those

non-federal landowners.

 

Cumulative impacts were considered.

40 CFR – 1508.7 CEQ – Regulations for Implementing NEPA

defines Cumulative (effects) impact as "Cumulative impact" is

the impact on the environment which results from the

incremental impact of the action when added to other past,

present, and reasonably foreseeable future actions regardless

of what agency (Federal or non-Federal) or person undertakes

such other actions. Cumulative impacts can result from

individually minor but collectively significant actions taking

place over a period of time.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 112 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The June 24, 2005 letter from CEQ regarding Guidance on the

Consideration of Past Actions in Cumulative Effects Analysis

stated, “The analysis of cumulative effects begins with

consideration of the direct and indirect effects on the

environment that are expected or likely to result from the

alternative proposals for agency action. Agencies then look for

present effects of past actions that are, in the judgment of the

agency, relevant and useful because they have a significant

cause-and-effect relationship with the direct and indirect

effects of the proposal for agency action and its alternatives. 

CEQ regulations do not require the consideration of the

individual effects of all past actions to determine the present

effects of past actions. Once the agency has identified those

present effects of past actions that warrant consideration, the

agency assesses the extent that the effects of the proposal for

agency action or its alternatives will add to, modify, or mitigate

those effects. The final analysis documents an agency

assessment of the cumulative effects of the actions

considered (including past, present, and reasonably

foreseeable future actions) on the affected environment.”

The FEIS considered the past actions from the planting of

invasive species to the number of undesignated trails within

Management Area 10C in Chapter 3, Environmental

Consequences. Understanding that there is the potential for

OHV riders to ride where it is not designated (off designated

routes in Management Area 10C or trespassing on private

property) the Forest plans on utilizing the three E’s, Education,

Engineering and Enforcement. The first step is Education

which would utilize maps and staff contacts. Engineering

includes such things as assurance markers, fencing and

signage. Enforcement would be used as described in the

FEIS. However, since it is not known where or how much

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 113 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

OHV riders may ride where it is not designated or where

trespass may occur, it is not possible to quantify the specific

environmental effects of these actions in a cumulative effects

analysis.

Eatherington, Francis The DEIS failed to consider the cumulative impacts to areas 

unauthorized trails that will become designated through this 

project. For instance, trespassing off the trail will increase 

once the trail is mapped as a designated trail. The DEIS 

should have looked at the areas adjoining newly designated 

trails and consider the impacts to native vegetation in those 

areas.

 

Cumulative impacts were considered.

40 CFR – 1508.7 CEQ – Regulations for Implementing NEPA

defines Cumulative (effects) impact as "Cumulative impact" is

the impact on the environment which results from the

incremental impact of the action when added to other past,

present, and reasonably foreseeable future actions regardless

of what agency (Federal or non-Federal) or person undertakes

such other actions. Cumulative impacts can result from

individually minor but collectively significant actions taking

place over a period of time.

The June 24, 2005 letter from CEQ regarding Guidance on the

Consideration of Past Actions in Cumulative Effects Analysis

stated, “The analysis of cumulative effects begins with

consideration of the direct and indirect effects on the

environment that are expected or likely to result from the

alternative proposals for agency action. Agencies then look for

present effects of past actions that are, in the judgment of the

agency, relevant and useful because they have a significant

cause-and-effect relationship with the direct and indirect

effects of the proposal for agency action and its alternatives. 

CEQ regulations do not require the consideration of the

individual effects of all past actions to determine the present

effects of past actions. Once the agency has identified those

present effects of past actions that warrant consideration, the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 114 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

agency assesses the extent that the effects of the proposal for

agency action or its alternatives will add to, modify, or mitigate

those effects. The final analysis documents an agency

assessment of the cumulative effects of the actions

considered (including past, present, and reasonably

foreseeable future actions) on the affected environment.”

The FEIS considered the past actions from the planting of

invasive species to the number of undesignated trails within

Management Area 10C in Chapter 3, Environmental

Consequences. Understanding that there is the potential for

OHV riders to ride where it is not designated (off designated

routes in Management Area 10C or trespassing on private

property) the Forest plans on utilizing the three E’s, Education,

Engineering and Enforcement. The first step is Education

which would utilize maps and staff contacts. Engineering

includes such things as assurance markers, fencing and

signage. Enforcement would be used as described in the

FEIS. However, since it is not known where or how much

OHV riders may ride where it is not designated or where

trespass may occur, it is not possible to quantify the specific

environmental effects of these actions in a cumulative effects

analysis.

Eatherington, Francis The 1994 DEIS did not consider the environmental impact of 

135 miles of illegally created routes through 10C, and this 

DEIS doesn325t either. When will that disturbance be

considered and mitigated for? Add to this the additional 

unauthorized trials through 10A,

10D, 10E, 10F, 10G, 10H, 10J, 10K, and 10L.

 

Cumulative impacts were considered.

40 CFR – 1508.7 CEQ – Regulations for Implementing NEPA

defines Cumulative (effects) impact as "Cumulative impact" is

the impact on the environment which results from the

incremental impact of the action when added to other past,

present, and reasonably foreseeable future actions regardless

of what agency (Federal or non-Federal) or person undertakes

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 115 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

such other actions. Cumulative impacts can result from

individually minor but collectively significant actions taking

place over a period of time.

The June 24, 2005 letter from CEQ regarding Guidance on the

Consideration of Past Actions in Cumulative Effects Analysis

stated, “The analysis of cumulative effects begins with

consideration of the direct and indirect effects on the

environment that are expected or likely to result from the

alternative proposals for agency action. Agencies then look for

present effects of past actions that are, in the judgment of the

agency, relevant and useful because they have a significant

cause-and-effect relationship with the direct and indirect

effects of the proposal for agency action and its alternatives. 

CEQ regulations do not require the consideration of the

individual effects of all past actions to determine the present

effects of past actions. Once the agency has identified those

present effects of past actions that warrant consideration, the

agency assesses the extent that the effects of the proposal for

agency action or its alternatives will add to, modify, or mitigate

those effects. The final analysis documents an agency

assessment of the cumulative effects of the actions

considered (including past, present, and reasonably

foreseeable future actions) on the affected environment.”

The FEIS considered the past actions from the planting of

invasive species to the number of undesignated trails within

Management Area 10C in Chapter 3, Environmental

Consequences. Understanding that there is the potential for

OHV riders to ride where it is not designated (off designated

routes in Management Area 10C or trespassing on private

property) the Forest plans on utilizing the three E’s, Education,

Engineering and Enforcement. The first step is Education

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 116 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

which would utilize maps and staff contacts. Engineering

includes such things as assurance markers, fencing and

signage. Enforcement would be used as described in the

FEIS. However, since it is not known where or how much

OHV riders may ride where it is not designated or where

trespass may occur, it is not possible to quantify the specific

environmental effects of these actions in a cumulative effects

analysis.

Eatherington, Francis This DEIS assumes that 135-miles of unauthorized trails in 

10C would be obliterated or

allowed to revert naturally. The DEIS failed to quantify what 

damage was done, if the

damage is fixable, or if permanent damage occurred. If the 

damage is fixable, how or

when will restoration occur? The DEIS should have disclosed if 

obliterating or allowed to

revert naturally is sufficient to halt the damage, restore the 

damage, or if the damage, such as erosion or spread of 

noxious weeds, would continue even after the trail is closed.

Please refer to FEIS, Chapter 3, Botanical Resources

Section. The damage was qualified as the planting of

European beachgrass, Scotch broom and shore pine to

stabilize the sand, dramatically changing the Dune

landscape. Within Management Area 10 (C) user-created

trails were quantified at about 135 miles. User-developed

trails that are non-vegetated and traverse areas of native

vegetation would likely re-colonize with the prevalent native

species in the area. Whether plants colonizing non-vegetated

areas of newly closed trails would be native or non-native

species depends in large part on what the dominant

vegetation in the adjacent area is. In the short-tem, restored

trails would likely re-vegate with native species as these tend

to establish faster on bare sand, but later areas could become

predominately non-native if it is what dominates the adjacent

areas.

Eatherington, Francis This DEIS should have considered all unauthorized trails, not 

just the 135-miles through

10C. There could be thousands of miles on the entire Oregon 

Dunes. What is the Forest

Service's commitment to enforcing the Dunes plan on all land 

allocations?

Restoration of user created routes in other management areas

other than MA 10 (C) is outside of the scope of this project.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 117 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Eatherington, Francis Most lakes in the ODNRA have active beaver populations. The 

DEIS failed to consider

the impacts of OHVs on the beaver population and other 

wildlife dependent on lakes in

the Dunes.

 

General effects of OHVs on wildlife are discussed in Chapter 3

of the Final Environmental Impact Statement of the Dunes

Management Plan. The Oregon Dunes NRA Management

Area 10 (C) Designated Routes Project does not propose an

increase in OHV access to lakes from the current condition. 

Lakes within the North Riding Area will remain within

Management Area 10 (C) and current user developed routes

accessing those lakes will be closed to future motorized use

and would be obliterated or allowed to naturally revert. This

action will decrease OHV impacts to aquatic dependent

wildlife species such as beaver. There are no lakes within the

project area in the Middle Riding Area. Lakes within the

South Riding Area are designated as Management Area 10

(H) – Plant, Fish and Wildlife Viewing and OHV effects to

those areas are outside the scope of the project. 

Eatherington, Francis All lakes and wetlands in the Dunes are riparian reserves 

under the Northwest Forest Plan. Riparian reserves overlay all 

other land allocations, such as administratively withdrawn 

lands, like the ODNRA. The EIS failed to discuss the acres of 

riparian reserves, including at least 150' around all lakes and 

wetlands that will be impacted by this project.

Please refer to FEIS, Chapter 3, Aquatic Conservation

Strategy Section.

Eatherington, Francis Snowy Plover: The DEIS failed to explain what would happen 

if newly designated trails or 10-B areas in the foredunes 

become sandy and attractive to Snowy Plovers. Snowy Plovers 

like to use newly created loose sand and tire tracks. How will 

the Snowy Plovers using this new habitat be impacted by 

increased motorized recreation?

 

All proposed routes exist on the ground as historic, userdeveloped routes. Areas that are proposed to change to

Management Area 10 (B) are currently functioning as 10 (B)

so changes to those habitats would be considered minor, so

little, if any, new habitat will be created. It is likely that overall

OHV use will gradually increase over time in Management

Areas 10 (B) and (C) but increases specific to rezone areas

are not expected. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 118 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Ely, Glenn Alternative 5 best. But please open user developed trails. No 

need to maintain user developed trails. The reason user 

developed trails are there is becausd, by most, these are the 

preferred riding areas. The open areas are not the preferred 

riding areas.

Varying acreages currently zoned as MA 10 (C) are proposed

for reallocation to open riding in Alternatives 2, 4, Modified

4 and 5 to accomodate trail riding in addition to riding in open

dunes. User-developed trails in areas that would be

reallocated to open riding would not be maintained as

designated routes.

Enlow, Sonja I would love to see the dunes restored to the 1950's era Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Ernst, Joann This would appear to be mitigation for closing illegal and 

unauthorized off-road vehicle routes through non-motorized 

areas of the dunes.

The rationale for proposals to reallocate areas from MA 10 (C)

to MA 10 (B) are discussed in Chapter 1 of the DEIS and FEIS

under the heading Purpose and Need for Action. The issue

of maintaining the trail riding experience was frequently

described in scoping comments and is further discussed in the

Recreation section of Chapter 3 of the DEIS and FEIS.

Ernst, Joann I am writing to let you know about my concerns with the 

proposed revision to the Oregon Dunes National Recreation 

Area management plan, which would expand areas for offroad vehicle use.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 119 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Felde, Michael Safety is a large concern and every few years, we lose riding 

area and the number of people riding grows.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Felde, Michael People riding bring dollars to their towns Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 120 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Felde, Michael Another concern is impact to environment and dune wildlife.

[...]The impact riders have in such small overall area cannot 

be significant.

Thank you for your comment. Please refer to the wildlife

analysis in Chapter 3 of the FEIS.

Felde, Michael Check out my photos on Facebook Thank you for your comment.

Felter, Fred any terrain open to OHV use is beyond undesirable, it is 

downright dangerous.[...]we like to hike in the dunes and, of 

course, find a huge amount of land virtually unusable for 

 ̈quiet activities ̈ like hiking

Restricting or reducing the number of acres managed for OHV

use at the ODNRA is outside the scope of this project. The

purpose and need of this project is to designate routes within

MA 10 (C). Approximately 46% of the ODNRA is managed for

OHVs to some degree. Of that 46%, about 21% is managed

for open riding in areas of open sand and 4,455 acres or 15%

are managed for OHVs on designated routes only. This

project addresses only those 4,455 acres. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 121 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Forrest, Dexter The land management under the proposed DEIS continues 

restricting OHV access rather than a logical approach of 

vegetation enhancement and dune management with 

recreation management as part of a coordinated strategy.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Forrest, Dexter So it seems a cognizant dissonance for a current DEIS to be 

presented at significant cost and effort when a well thought 

out revision plan next year should invalidate it and open the 

dunes back up to the public

At one time the Siuslaw national Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Forrest, Dexter why aren’t the recreationists contribution to the economy 

recognized as a legitimate use of sustainable public land?

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 122 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 123 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Fouch, Timothy dune access by motorized vehicles should be SHARPLY 

RESTRICTED.[...]These vehicles are a nuisance; noisy, 

polluting and dangerous.

Restricting or reducing the number of acres managed for OHV

use at the ODNRA is outside the scope of this project. The

purpose and need of this project is to designate routes within

MA 10 (C). Approximately 46% of the ODNRA is managed for

OHVs to some degree. Of that 46%, about 21% is managed

for open riding in areas of open sand and 4,455 acres or 15%

are managed for OHVs on designated routes only. This

project addresses only those 4,455 acres. 

Frewing, John None of the alternatives mention, discuss or compare and 

evaluate the negative

effects which they impose on the alternative uses of ODNRA -- 

hiking.[...]Changing 1 0©

areas to 1 O(B) areas reduces the space available to hikers 

without actual interference

from OHVs on any specific day.

Please refer to the discussion of non-motorized recreation,

including hiking at the ODNRA in the Recreation section of

Chapter 3 of the DEIS and FEIS. Little non-motorized activity

takes place within areas of concentrated motorized

use. While 46% of the ODNRA is managed to some degree

for motorized activity, approximately 54% prohibits motorized

use and includes areas open to non-motorized activities

including hiking in the 5,930 acres managed as MA 10 (A). MA

10 (A) will not be affected by this project.

Frewing, John The DEIS should evaluate conflict with hikers and propose 

route and area restrictions

to minimize this conflict.

Little hiking occurs in the areas managed for motorized use.

No changes are proposed for non-motorized areas of the

Dunes wherein the vast majoritiy of non-motorized recreation,

including hiking, occurs. User conflicts are discussed on in the

Recreation section in Chapter 3 of the DEIS and EIS including

noise impacts to nearby quiet recreation.

Frewing, John One alternative would be to enforce the current limitations on

OHV use. Please estimate the resources to accomplish this.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 124 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 125 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Frewing, John With expanded authorized OHV presence on the ODNRA, 

there will be additional

probability of trash problems(page 138).

With increased miles of trails and areas enforced as closed,

the Forest expects a reduction in the amount of trash. Over

the past several years, with the implementation of the

designated sand camp program, trash has been significantly

decreased due to the permit process and our ability to write

citations for campers who leave trash in their registered sand

camps. 

Frewing, John The DEIS should address the matter of trash

management, including the effect of creating whole areas of 

unrestricted OHV use.

With increased miles of trails and areas enforced as closed,

the Forest expects a reduction in the amount of trash. Over

the past several years, with the implementation of the

designated sand camp program, trash has been significantly

decreased due to the permit process and our ability to write

citations for campers who leave trash in their registered sand

camps. 

Fromdahl, Debra opposing the proposed options Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 126 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Fromdahl, Debra failure to coordinate with affected counties (Douglas, Coos 

and Lane)[...]RACC respectfully requests the DEIS be 

withdrawn and that the USFS conduct and issue a , 

supplemental EIS seeking additional input and including better 

alternatives than those presented in the I current DEIS.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Fromdahl, Debra apparent lack of consideration of the legislative intent of the 

National Recreation Area Act-to manage for OHV access and 

recreational use.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 127 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Fromdahl, Debra concern regarding the public safety issues related to the 

options proposed in the DEIS, as expressed by local law 

enforcement officials.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Fromdahl, Debra However, as an organization focused on economic viability 

and job growth in our region, we have an even greater 

concern of the significant and adverse economic impacts 

current DEIS proposals would have on Oregon's coastal 

communities in Douglas, Coos and Lane counties.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 128 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Fry, Tony PLEASE do not close off any more riding areas/acres that we 

currently have.[...]everyone I meet from other parts of the 

country love coming and visiting the OR dunes because of the 

variety of terrain and especially the trails and views.[...]We 

enjoy the trails that are on the east side of the dunes that go 

down to the lakes, quite often we see wild life back in the 

woods and lakes. Another set of trails that we ride a lot when 

they are not flooded out are the trails that lead out of the flats 

just south of Goosepasture parking lot and connect up with 

the main dunes by one of the beach roads, and off course the 

beach trails are a fun source of riding also.[...]We support the 

local communities by buying our gas, parts, atv’s, and local 

dining options in each one of these areas.

No alternatives propose closing any open riding areas. The

alternatives would designate routes and areas in the 4,445

acres of Management Area 10 (C), as directed in the

1994 Dunes Plan. In MA 10 (C), OHVs are permitted on

designated routes only. Alternative 5 proposes to reallocate a

portion of Management Area 10 (C) just to the west of

Cleawox Lake and Bear Lake (A12).

Fry, Tony Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 129 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

More closure would only deter me and others from wanting to 

spend the extra fuel and time to go this far south and ride the 

dunes.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 130 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Gibreau, Marvin The routes or roads that are there now are fine. They do not 

need to be closed or changed.[...]Just leave the dunes alone 

& they will be fine, O.K.

Thank you for your comment.

Gilles, Nicole Nicholas the Draft Environmental Impact Statement for the Oregon 

Dunes 10c Designated Routes Project, we have found that it 

fails to adequately address the following issues; loss of OHV 

opportunity, outdated and flawed 1994 Dunes Plan, 

"minimiazation," impacts to upcoming forest plan revision, 

coordination with counties, purpose and need, local economic 

impact, vegetation management, and loss of agency credibility 

in the community.

Please refer to the responses to comments on pages 21-30 of

Appendix A, that respond to NEPA compliance, loss of OHV

opportunity, public participation, Forest Plan revision, public

involvement and vegetation management.

Gilles, Nicole Nicholas In the past 39 years, Off Highway Vehicle use has been 

reduced from 28,000 acres down to just below 6,000 acres. 

This means that only 20% of the NRA is available for legal 

OHV use at this time![...]The DEIS is fatally flawed since it is 

based on the 1994 Dunes Plan, which was created without 

legally required input from an NRA advisory council.[...]Also, 

the 1994 Plan is well beyond its useful period of l0-15 years as 

identified within the plan. The plan also states that the Forest 

Supervisor shall review the plan every five years to determine 

if conditions or public demands have changed significantly.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective on June 10,

1977, in accordance with the provisions of the federal

Advisory Committee Act (FACA) of 1972 (Public Law 92-463).

The Dunes Plan was prepared according to Secretary of

Agriculture regulations (36 CFR 219) which are based on the

Forest and Rangeland Renewable Resources Planning Act

(R_A) as amended by the National Forest Management Act of

1976 (NFMA). The Dunes Plan was also developed in

accordance with regulations (40 CFR 1500) for implementing

the National Environmental Policy Act of 1969 (NEPA).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 131 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Gilles, Nicole Nicholas The timlng of this project is suspect since a Forest revision is 

scheduled for 2014. We.are concerned that this project frontload or taint the upcoming revision with a predetermined 

"closure-orlented" outcome and/or restrict active management 

options (induding reopeming some areas to "Open OHV" use) 

to help arrest the spread of non-native vegetation into the 

sand dunes.

At one time the Siuslaw National Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Gilles, Nicole Nicholas Vegetation and dune management should dovetail with 

recreation management as part of a coordinated strategy.[...]

The project should address active and effective vegetation 

management alternatives, which can complement, and 

potentially be enhanced by effective recreation management. 

In short the Oregon Dunes present a ·unique situation 

where,active sand dunes should be a desired condition and 

encroachment of non-native vegetation is a "significant issue" 

that must be addressed.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 132 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Gilles, Nicole Nicholas The purpose and need should have been broadened to 

address the legislative intent of the original National 

Recreation Area Act.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Gilles, Nicole Nicholas These are but a few reasons we ask that you please withdraw 

the current DEIS and associated public comment period, 

conduct a supplemental analysis and issue a supplemental EIS 

to include and seek input on additional alternatives to those. 

presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 133 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 134 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Glass, Stephanie reconsider any action to further reduce the acreage available 

to open OHV use in your parks.

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Glass, Stephanie Please appreciate the importance of family recreation at low 

cost

Thank you for your comment.

Glover, Robert The timing of this project is suspect since a Forest revision is

scheduled for 2014

At one time the Siuslaw National Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 135 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Glover, Robert The agency failed to coordinate with affected counties in this 

EIS and

the 1994 Dunes Plan.[...]want to ensure the ODNRA is 

following

administration directives and has actively considered 

designation of

federal and non-federal cooperating agencies in the 

preparation of

analyses and documentation required by the National 

Environmental

Policy Act (NEPA). I also want to ensure that Federal agencies

actively participate as cooperating agencies in other agency's 

NEPA

processes.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Gorsuch, Geoff Please withdraw the current DEIS and associated public 

comment period, conduct supplemental analysis and issue a 

supplemental EIS to include and seek input on additional 

alternatives to those presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 136 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 137 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Gorsuch, Geoff OHV recreation has already been "minimized" enough by 

previous NEPA decisions.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 138 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 139 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 140 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 141 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Gorsuch, Geoff In 1972, approximately 28,000 acres were open for legal OHV 

use. After implementation of the 1979 ODRNA Management 

Plan, the acreage available for OHV use was reduced, by 

about 47%, down to 15,000 acres. When the 1994 ODNRA 

Management Plan was adopted, the acreage available for 

open riding was reduced significantly to 5,930 acres.[...]

Between 1972 and 2011, the acreage available for open OHV 

use has been reduced from 28,000 acres down to just below 

6,000 acres. Just 20 percent of the NRA is available for legal 

OHV use today.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 142 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations: • South Jetty Big Dune area. • South Jetty parking lot #1. • Siltcoos Beach parking lot. • Tenmile Creek parking lot.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 143 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 144 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 145 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 146 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Gorsuch, Geoff After implementation of the 1979 ODRNA Management Plan, 

the acreage available for OHV use was reduced, by about 

47%, down to 15,000 acres. When the 1994 ODNRA 

Management Plan was adopted, the acreage available for 

open riding was reduced significantly to 5,930 acres.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 147 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 148 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 149 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 150 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 151 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Granat, Amy Non-compliance with the original conditions set out in the 

1994 Dunes Plan. The

aforementioned plan called for the designation of additional 

motorized use in the National

Recreation Area. Because of the agency’s own failures, while 

the need for additional routes

was obviously noted and determined in 1994, the lack of 

forthcoming action on behalf of the

Forest Service caused the public to steps on its own, and a 

series of routes were developed to

suit the public’s needs.

As described in the FEIS, the Dunes Plan directed that

additional designated routes be identified within 3 years. Due

to other management priorities, the designation of additional

routes in the 4,455 acres of MA 10 (C) did not occur. As

further stated in the FEIS, without a complete formal route

system or adequate signing and closure order for most of MA

10 (C), use of undesignated routes and establishment of

additional user-developed routes continues. This project

would designate those additional routes in MA 10 (C). 

Granat, Amy the popularity off-highway vehicle

use has skyrocketed. To correctly accommodate this use, the 

agency would have been correct

to designate many more routes in the Oregon Dunes. By 

abdicating this responsibility, the

Forest Service left a dearth of leadership which the motorized 

public has filled for close to 20 years. Now, in an attempt to 

reassert itself, the agency is proposing to close over 100 miles 

of routes, and significantly change the way the public 

accesses the dunes in the open areas.

The Forest is not proposing any closures to OHVs in open

riding areas. This project would designate routes in the 4,455

acres of Management Area 10 (C) only, an area managed for

OHVs on designated routes only, as directed by the 1994

Dunes Plan.

Granat, Amy There is a mistaken perception reiterated throughout the DEIS 

that restricting motorized will

result in lesser amount of environmental impacts

The impacts of OHVs to vegetation, wildlife, fisheries and

hydrology are documented in the DEIS, FEIS and in the

specialist reports. 

Granat, Amy The Forest Service must

plan to increase roads and trails in order to disperse travel.

Alternatives 2, 3, 4, Modified 4 and 5 propose increasing

designated routes; and alternatives 2, 4, Modified 4 and 5

propose reallocating areas to open riding, thereby increasing

trails upon which OHVs are permitted. Road managment

decisions are outside the scope of this project.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 152 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Granat, Amy choosing an alternative that requires more

manpower and money for maintenance does not make good 

economic sense.[...]This impact is

not evaluated in the DEIS, therefore it presents a fatal flaw in 

the document. Therefore the

DEIS should be remanded, and the Forest Service should work 

with the motorized public to a

greater extent and leave their preconceived notions at the 

door to develop a plan for more

routes and open areas to disperse motorized activity, thereby 

reducing any possible

environmental impacts.

The Forest is proposing this project to fulfill the 2005 Travel

Management Rule and the direction of the 1994 Dunes Plan.

An alternative will be selected to meet the Forest's legal

requirements to designate routes and areas as open to

motorized use based on sound resource management

practices. Part of the purpose and need for this project is to

simplify OHV management within MA 10 (C), allowing agency

personnel to focus more time and effort on visitor education,

resource restoration and strong enforcement.

Granat, Amy Please refer to FEIS, Chapter 3, Botanical Resources where it

states, "Non-native invasive plants are spread by wind, water,

animals, and people. one mechanism of plant spread is

vehicles that pick up sees and plant parts on their tires, body,

and chassis, transporting them to other locations where they

drop off and potentially start new infections. No specific

information was found that looks at the role OHV's may have

in the spread of invasive plants in the ODNRA. Else where, it

has been shown that vehicles do spread invasive plants, and

that potential to transport seed increases when the vehicle

travels off-road, and that the amount of seed that is carried by

the vehicle increases in wet conditions (MSU 2011). Because

sandy soils do not stick to vehicles in the same way as finer

loam or clay, the results of these studies may not be directly

appliciable to conditions in the project area, but some seed

transport by vehicles cannot be ruled out as well as the

potential to introduce seed from other areas outside of the

ODNRA where the vehicle may have been. The potential to

introduce or spread invasive plants by vehicle and what

degree of impact that has on other resources can be ranked.

Designating areas of largely native vegetation to open OHV

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 153 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Equating the spread of invasive or non-native species on 

motorized routes: The DEIS

constantly talks of the spread of invasive or non-native 

species in the same breath as

motorized recreation, leading the reader to presume that 

motorized recreation has caused

non-native species to proliferate around the dune 

environment. These are two difference

issues that deserve to be studied in two separate documents. 

Non-native species in a dune

environment can be spread by many different methods but to 

presume that motorized

recreation routes are the cause, or indicating that restricting 

motorized vehicle use will

suddenly result in a reduction of non-native species borders 

on the absurd.[...]All reference to motorized recreation either

being a cause of invasive species, or the inference that the 

limitation of motorized use will

affect an improvement of this problem must be stricken from 

the document. It is a naïve

assumption at best, or based on incorrect scientific analysis at 

worst.

use would have the greatest risk of impact, followed by new

construction of designated routes through native vegetation

within Management Area 10 (C), designating an existing userdeveloped trail within native vegetation, and least impacting,

designating a user-developed trail through non-native

vegetation or opening an area of non-native vegetation to

open OHV use." It also states, "Intensive OHV use can reduce

or eliminate the colonization of invasive European beachgrass

and an argument could be made that reallocating areas from

Management Area 10 (C) to 10 (B) may provide some control

of this species. To be effective however, high frequency and

duration of use would need to be maintained over an entire

area. Because areas proposed for reallocation were selected

for their potential to provide trail riding opportunities, use

patterns would not likely result in any real reduction in

European beachgrass."

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 154 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Granat, Amy The no-action alternative is not a true no-action alternative as 

defined by NEPA regulation: A no-action alternative takes the 

conditions on the ground as a baseline default, the DEIS did 

not follow this directive. Instead, the non-action alternative 

actively omitted what was called ‘use-created’ routes.

The no-action alternative provides a baseline for estimating

the effects of other alternatives. A no action alternative is

required in an EIS (40 CFR 1502.14(c)). The no-action

alternative portrays the implementation of the 2009 Siuslaw

Travel Management Project Decision. The implementation of

this Decision would be the closure of motorized vehicle

use within Management Area 10C except for the designated

routes that were identified in the Plan and displayed in the

Motor Vehicle Use Map. The 2009 Siuslaw Travel

Management Plan recognized the lack of designated routes

and deferred implementation of the Plan within Management

Area 10C until the completion of the Designated Routes

Project. The existing condition is described, but it does not

meet the purpose and need. The FEIS, Chapter 3,

Environmental Consequences describes the existing condition

in the affected environment for the resources, but only

describes direct, indirect and cumulative effects for the

alternatives considered, including the No Action Alternative.

Granat, Amy The Forest Service must take a close look on the ground at 

the uses the community developed that clearly suited their

needs for recreational travel, and then create a plan that 

accommodates and expands upon

this need while creating a management plan for invasive 

species, snowy plover, and other

desired environmental conditions.

The Forest followed laws, policies and regulations in soliciting

input for this project. The Siuslaw National Forest began

seeking information from the public in regard to the

Designated Routes project in 2009, when the Forest hired an

independent contractor to assemble and facilitate a working

group of individuals with varied interests in the Oregon Dunes.

In 2010, this working group provided ideas regarding a system

of designated trails and open riding areas that they believed

would meet the 1994 Dunes Plan. The results of their work

was posted to the Forest website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 155 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 130 comments on the DEIS.

Granat, Amy Rider safety is another area that has been purposely ignored 

in the DEIS. By concentrating use

on fewer and fewer trails and open areas, the Forest Service 

is actually raising the likelihood of rider collision and or 

conflict. Because all types of motorized vehicles are used in 

the Oregon Dunes National Recreation Area, different abilities 

of drivers and riders using different vehicles are likely.[...]

Therefore the more concentrated the use, the more 

probability there is for accidents or collision. It is a clear 

connection. Because the safety issue has been incorrectly 

eliminated for study in the document, the DEIS must be 

remanded for further analysis and a supplemental DEIS 

prepared.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

The National Environmental Policy Act provides the Forest

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 156 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Granat, Amy The DEIS does not have buy-in from the community or the 

surrounding cities and residents, leading to the conclusion 

that the agency will not achieve the goals outlined in the 

Purpose and Need of the DEIS. As the Purpose and Need 

cannot be achieved with the current document, the Forest 

Service must remand this DEIS and continue their analysis to 

develop a plan with a greater likelihood of success

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 157 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Granat, Amy CORVA encourages the Forest Service to go back to the 

drawing board and produce a supplemental DEIS that will 

garner the support of the entire dune community.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 158 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 159 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Granat, Amy To use terminology such as ‘user-created’ routes throughout 

the document assumed that there

was active management by the agency, and members of the 

public defied management rules.

The term "user-created" trails defines trails that have not been

designated, numbered or mapped by the Forest Service. It is

true that many of these trails existed prior to the 1979 or the

1994 Dunes Plans. However, both Plans envisioned a

designated route system through vegetated areas. This vision

was not fulfilled. With the 2005 Travel Management Rule,

forests were directed to designate roads, trails and areas that

are open to motorized travel. This was a change from forests

being open to motorized travel unless designated

closed. Management Area 10C was designated closed except

for designated routes in the 1994 Dunes Plan, however this

was not fully implemented. It was recognized during the

development of the Siuslaw Travel Management

Environmental Assessment that due to the fact that trails were

not designated, many areas on the ODNRA were not legally

accessible. This FEIS attempts to bring the ODNRA into

compliance with the 2005 Travel Management Rule by

designating trails and open areas within Management Area

10C and to make the designations comprehensive and

understandable that can be effectively managed and

maintained.

Granat, Amy Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 160 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Visitation/economic effects and rider safety were excluded 

from the analysis: The DEIS

randomly excludes the cumulative financial effects on 

surrounding dune communities, as well

as rider safety concerns from the document by incorrectly 

stating that these cannot be

analyzed by the Forest Service. Because all cumulative effects 

of a proposed action must be

determined by the agency before it moves forward with a 

plan, the conclusion reached in this

case that agency is not responsible for either of the above 

concerns is incorrect. Visitation to the dunes is an ongoing 

concern of the surrounding communities and the basis for 

much of

their economic well-being.

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 161 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Granat, Amy The Forest Service has not chosen to engage with these

communities sufficiently to take their needs into account in 

this DEIS, however this fact does

not alleviate the agency of its responsibility to do so. In fact, 

the agency has the duty to

engage local governments and residents in the development 

of a management plan to ensure

that these entities are not adversely affected by the proposed 

action.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Grant, Roxana I write this letter in opposition to the closures proposed for 

the Douglas County Dunes[...]opposed to this closure of riding 

areas

Please refer to Response #47.

Grant, Roxana huge impact on some of our Downtown

businesses. This type of impact has far reaching economic 

downside.[...]Local business would be affected.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 162 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Grant, Roxana 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 163 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

When the Congress gifted the lands for recreational use, I am 

sure they did not mean for it to be given and then taken 

away. I base this on the "minimization" by previous NEPA 

decisions. Ie: 1970 ODRNA Management Plan, reduction by 

approx 47%, down to 15000 acres. 1994 ODRNA 

Management Plan adoption another reduction of 5930 acres. 

The 10 (C) zoning creates an illusion that 4455 acres of 

designated routes are available for OHV use, reality is only 10 

miles of designated routes exist in Zone 10 (C) that acreage is 

reduced to less than 1 acre(actualland footprint of the routes). 

Between 1972 and 2011 the acreage available for riding has 

been reduced from 28000 acres down to just below 6000 

acres. 20% of the NRA is available for legal OHV use today. 

(BRC 20 13)[...]Riding areas are disappearing faster than they 

are being created

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 164 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 165 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 166 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 167 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Gross, Kathleen The proposed DEIS significantly impacts our business and we 

have strong opinions on the proposed changes.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 168 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Gross, Kathleen They like the trail riding opportunities that the Oregon Dunes 

offer and feel safe bringing their families to play on our area 

of the coast. These families have responded very positively to 

the alcohol ban which helped protect their children but now 

are very concerned their wholesome family adventures will be 

restricted.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Gross, Kathleen 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 169 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

We believe that OHV recreation has already been "minimized" 

enough by previous NEPA decisions. It is our understanding 

that the following events since 2011 have reduced OHV usage 

from 28,000 acres down to just below 6000 acres. As we 

understand the ODNRA history, in 1972, approximately 28,000 

acres were open for legal OHV use. After implementation of 

the 1979 ODRNA Management Plan, the acreage available for 

OHV use was reduced, by about 47%, down to 15,000 acres. 

When the 1994 ODNRA Management Plan was adopted, the 

acreage available for open riding was reduced significantly to 

5,930 acres. The agency in Zone 10 (C) attempts to create 

the illusion that 4,455 acres of designated routes are available 

for OHV use. However, since only about 10 miles of 

designated routes exist in Zone 10 (C) that acreage is reduced 

to less than an acre (actual land footprint of the routes). Just 

20 percent of the NRA is available for legal OHV use today.

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 170 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

7. Secretary of Agriculture Regulation 36 CFR 295.6 -

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 171 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 172 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 173 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Gross, Kathleen The first issue is the European Beach Grass which has become 

an invasive species. It’s continual invasion into the dunes is a 

malignant transformation of areas of the dunes. What many 

people have not acknowledged is the OHV vehicles have 

played an important part in keeping the beach grass from 

wiping out areas of the dunes. If you go out into areas that 

have been restricted to vehicular traffic, you can see this 

drastic loss of the trail areas. It seems to us that the DEIS 

plan is backwards—the invasive species issue should be 

addressed before deciding on more closures.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Gross, Kathleen Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 174 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The second issue is the tremendous economic support the 

OHV industry brings to Oregon. The obvious positive benefits 

to the surrounding communities near the Oregon Dunes 

National Recreation Area are clear. These guests buy gasoline, 

food, vehicle parts, go to the movies, and partake in all 

normal vacation activities. What must be remembered is 

ODNRA guests have a significant economic effect to the entire 

state of Oregon. Specifically, I think the OHV visitor’s huge 

economic benefit to Oregon has been forgotten. Their dollars 

can help fund projects which can be designed to preserve the 

Dunes well into the future and still provide them with a great 

vacation experience.

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 175 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Gross, Kathleen In our opinion, the optimal action on the DEIS plan would be 

to leave the trail and access unchanged. That is obviously not 

going to happen so we would request adopting a plan that 

would re-examine your current recommendations and either 

a.) set in motion a new plan that would even more minimally 

restrict the current riding areas or b.) adopt the least 

restrictive of the current options.

An alternative that would designate all existing user-developed

routes is discussed in the DEIS and FEIS as an Alternative

Considered but Eliminated from Detailed Study.

Gross, Kathleen and Francis The proposed DEIS significantly impacts our business and we 

have strong opinions on the proposed changes.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 176 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Gross, Kathleen and Francis They like the trail riding opportunities that the Oregon Dunes 

offor and feel safe bringing their families to play on our area 

of the coast. These families have responded very positively to 

the alcohol ban which helped protect their children but now 

are very concerned their wholesome family adventures will be 

restricted.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Gross, Kathleen and Francis 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 177 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

We believe that OHV recreation has already been "minimized" 

enough by previous NEPA decisions. It Is our understanding 

that the following events since 2011 have reduced OHV usage 

from 28,000 acres down to just below 6000 acres. As we 

understand the OONRA history, In 1972, approximately 

28,000 acres wero open for legal OHV use. After 

Implementation of the 1979 ODRNA Management Plan, the 

acreage available for OHV use was reduced, by about 47%, 

down to 15,000 acres. When the 1994 ODNRA ManagemQnt 

Plan was adopted, the acreage available for open riding was 

reduced significantly to 5,930 acres. The agency In Zone 10 

(C} attempts to create the illusion that 4,455 acres of 

designated routes are available for OHV use. However, since 

only about 10 miles of designated routes exist In Zone 10 (C) 

that acreage is reduced to less than an acre (actual land 

footprint of the routes). Just 20 percent of the NRA is 

available for legal OHV use today.

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 178 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 179 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 180 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 181 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Gross, Kathleen and Francis The first issue is the European Beach Grass which has become 

an invasive species. It's continual invasion Into the dunes Is a 

malignant transformation of areas of the dunes. What many 

people have not acknowledged is the OHV vehicles have 

played an important part in keeping the beach grass from 

wiping out areas of the dunes. If you go out into areas that 

have been restricted to vehicular traffic, you can see this 

drastic loss of the trail areas. It seems to us that the DEl$ 

plan is backwards-the invasive species issue should be 

addressed before deciding on more closures.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Gross, Kathleen and Francis The second issue is the tremendous economic support the 

OHV Industry brings to Oregon. The obvious positive benefits 

to the surrounding communities near the Oregon Dunes 

National Recreation Area are clear. These guests buy gasoline, 

food, vehicle parts,go to the movies, and partake In all normal 

vacation activities. What must be remembered is ODNRA 

guests have a significant economic effect to the entire state of 

Oregon. Specifically, I think the OHV visitor's huge economic 

benefit to Oregon has been forgotten. Their dollars can help 

fund projects which can be designed to preserve the Dunes 

well Into the future and still provide them with a great 

vacation experience.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 182 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 183 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Gross, Kathleen and Francis In our opinion, the optimal action on the DEIS plan would be 

to leave the trail and access unchanged.[...]That Is obviously 

not going to happen so we would request adopting a plan that 

would re-examine your current recommendations and either 

a.) set in motion a new plan that would even more minimally 

restrict the current riding areas or b.) adopt the least 

restrictive of the current options.

An alternative that would designate all existing user-developed

routes is discussed in the DEIS and FEIS as an Alternative

Considered but Eliminated from Detailed Study.

Guido, Katie Our family has been riding at the dunes for generations and 

we prefer riding “trails” as opposed to the large “open” dunes.

Alternatives 2, 4, Modified 4 and 5 propose reallocations to

provide trail riding opportunities.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 184 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Katie First of all, I must address the major deficiencies; the first and 

most important being that the draft has not addressed other 

viable alternatives in detail.

No specific number of alternatives is required (42 USC 4332,

102(c)(iii) and E, 36 CFR 220.b(2)), but rather alternatives are

driven by cause-and-effect-statements. The range of

reasonable alternatives includes both alternatives that warrant

detailed analysis and alternatives that are considered, but

eliminated from detailed study. The Forest Service developed

five alternatives, including the No Action alternative, in

response to the issues raised by the public, by other agencies

and internally. Two additional alternatives were considered

but eliminated from detailed study. Alternatives provide

different ways to fulfill the purpose and need and address

unresolved conflicts related to the proposed action. All

alternatives are discussed in chapter 2 of DEIS and FEIS,

including issues that drove the development of alternatives

and a table comparing alternatives. 

In response to comments on the DEIS, an additional

alternative, Modified 4 was developed. Including the No

Action Alternative, five alternatives to the proposed action

were developed. 

Guido, Katie In contrast, by closing most of the existing trails, common 

sense would indicate that a serious safety issue arises. Fewer 

trails will result in more users on each of the remaining open 

trails or area.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 185 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Katie One of these alternatives would be to take into consideration 

that the open riding areas existing in 1972 and before, have 

been encroached upon by non-native plants (i.e. bench grass 

and scotch broom to name a few). This has resulted in a 

dramatic further reduction in the ATV riding area.

Changes to open riding areas of MA 10 (B) are outside the

scope of this project. Please refer to response #3 for a

discussion of Dune Restoration and the steps the Forest is

taking to address the advancement of non-native vegetation. 

The Forest has compiled 1979 aerial photos of the three riding

areas. We had incomplete photo coverage for 1972

photos. Those photos were then overlayed with the

boundaries of MA 10 (C) to determine the amount of formerly

open sand that is now included in MA 10 (C). This overlay

revealed that the amount the areas of open sand in 1979

coordinate closely with the areas of open riding in MA 10 (B),

and that the areas that appeared vegetated in 1979 are the

areas that are now MA 10 (C). Review of those photos, does

however show that there has been expansion of the deflation

plain westward, as suspected and that although the areas of

vegetation appear very similar, the density of the vegetation

has increased. It is important to acknowledge that this does

not mean areas of open sand have not been diminished by the

advancement of non-native vegetation; what appeared to be

open sand in 1979, now appears to have more areas of

European beachgrass and Scotch broom. 

Guido, Katie the Forest Service should look into EXPANDING the 

designated routes/trail through some of the “forested” areas.

Alternatives 2, 3, 4, Modified 4 and 5 propose additional

routes in vegetated areas.

Guido, Katie Another alternative that was not addressed would be to add 

more riding area through the closed area between Spinreel 

campground and Winchester Bay riding areas (the way it was 

originally).[...]This area need not be totally closed to protect 

the snowy plover, etc.[...]Perhaps there could even be a 

corridor through this area, which would not infringe on any 

sensitive areas.

It is outside the scope of this analysis to rezone any areas not

within Management Area 10 (C).

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Oregon Dunes National

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 186 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Recreation Area currently has about 34 miles of designated

trails and about 5,930 acres of designated areas for open

motorized travel. As the Siuslaw National Forest developed its

2009 Travel Management Plan, it became apparent that since

not all the MA 10 (C) routes had been designated, some areas

within the motorized portions of the ODNRA were largely

inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10C to motorized cross-country travel and

allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Three alternatives (2, 4, and 5) analyze rezoning Management

Area 10C (designated routes only) to Management 10B (open)

in varying degrees. 

Guido, Katie 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 187 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The E.I.S. has not addressed the fact that of the 28,900 acres 

in the ODNRA that Congress designated “to provide for the 

public outdoor recreation use” only 11,435 remain open to 

ATV use, which is contrary to Congress’ original intent.[...]

Also, not mentioned is in the original 1972 Congressional Act, 

an “Advisory Council” was called for but to my knowledge was 

not implemented, nor does it exist today.

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 188 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

7. Secretary of Agriculture Regulation 36 CFR 295.6 -

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 189 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 190 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 191 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 192 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Katie change the 10(C) areas to 10(B) designation, “open riding” 

except for the bonafide wetlands.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Guido, Katie most of the trails in the 10(C) designated areas today are a 

result of encroachment of non-native species into the 

historically open riding areas

Areas of user-developed routes in MA 10 (C) occur in a

variety of vegetation in the ODNRA including plantations,

native vegetation and areas dominated by non-native

species. Please refer to Response #142 for a discussion on

existing vegetation in MA 10 (C) and its relationship to open

sand at the time the ODNRA was established.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 193 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Katie the Forest Service simply does not have the resources to 

supervise and maintain these trails, a simple change in 

designation would solve many problems.

 

The Forest recognizes the need for upfront education and

enforcement of the designated routes decision to inform OHV

riders of routes open to motor vehicle use. Enforcement of the

trail system will be improved through signage, unauthorized

route closure, and regular patrols. Public compliance is

expected to increase with the formal designation of a more

understandable trail system connecting OHV riders to

beaches, open sand areas, and designated sand camps. Trail

operation and maintenance will be funded through Forest

Service appropriated funds, recreation fee revenues

generated in the Oregon Dunes NRA, and partnership funds

from the Oregon Parks and Recreation ATV grant

program. Cooperative law enforcement will continue to

address public safety issues. 

Guido, Katie What limited other maintenance that might be required could 

be achieved by turning the day-to-day operation over to each 

respective County Parks departments, who in turn would form 

a public/private cooperative effort between the county and 

clubs, organizations, and other interested citizens.

Land exchanges are outside the scope of this project.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 194 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Kelly First of all, I must address the major deficiencies; the first and 

most important being that the draft has not addressed other 

viable alternatives in detail.

No specific number of alternatives is required (42 USC 4332,

102(c)(iii) and E, 36 CFR 220.b(2)), but rather alternatives are

driven by cause-and-effect-statements. The range of

reasonable alternatives includes both alternatives that warrant

detailed analysis and alternatives that are considered, but

eliminated from detailed study. The Forest Service developed

five alternatives, including the No Action alternative, in

response to the issues raised by the public, by other agencies

and internally. Two additional alternatives were considered

but eliminated from detailed study. Alternatives provide

different ways to fulfill the purpose and need and address

unresolved conflicts related to the proposed action. All

alternatives are discussed in chapter 2 of DEIS and FEIS,

including issues that drove the development of alternatives

and a table comparing alternatives. 

In response to comments on the DEIS, an additional

alternative, Modified 4 was developed. Including the No

Action Alternative, five alternatives to the proposed action

were developed. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 195 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Kelly One of these alternatives would be to take into consideration 

that the open riding areas existing in 1972 and before, have 

been encroached upon by non-native plants (i.e. bench grass 

and scotch broom to name a few). This has resulted in a 

dramatic further reduction in the ATV riding area.

Changes to open riding areas of MA 10 (B) are outside the

scope of this project. Please refer to response #3 for a

discussion of Dune Restoration and the steps the Forest is

taking to address the advancement of non-native vegetation. 

The Forest has compiled 1979 aerial photos of the three riding

areas. We had incomplete photo coverage for 1972

photos. Those photos were then overlayed with the

boundaries of MA 10 (C) to determine the amount of formerly

open sand that is now included in MA 10 (C). This overlay

revealed that the amount the areas of open sand in 1979

coordinate closely with the areas of open riding in MA 10 (B),

and that the areas that appeared vegetated in 1979 are the

areas that are now MA 10 (C). Review of those photos, does

however show that there has been expansion of the deflation

plain westward, as suspected and that although the areas of

vegetation appear very similar, the density of the vegetation

has increased. It is important to acknowledge that this does

not mean areas of open sand have not been diminished by the

advancement of non-native vegetation; what appeared to be

open sand in 1979, now appears to have more areas of

European beachgrass and Scotch broom. 

Guido, Kelly the Forest Service should look into EXPANDING the 

designated routes/trail through some of the “forested” areas.

Alternatives 2, 3, 4, Modified 4 and 5 propose additional

routes in vegetated areas.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 196 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Kelly In contrast, by closing most of the existing trails, common 

sense would indicate that a serious safety issue arises. Fewer 

trails will result in more users on each of the remaining open 

trails or area.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Guido, Kelly Another alternative that was not addressed would be to add 

more riding area through the closed area between Spinreel 

campground and Winchester Bay riding areas (the way it was 

originally).[...]This area need not be totally closed to protect 

the snowy plover, etc. Perhaps there could even be a corridor 

through this area, which would not infringe on any sensitive 

areas.

It is outside the scope of this analysis to rezone any areas not

within Management Area 10 (C).

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Oregon Dunes National

Recreation Area currently has about 34 miles of designated

trails and about 5,930 acres of designated areas for open

motorized travel. As the Siuslaw National Forest developed its

2009 Travel Management Plan, it became apparent that since

not all the MA 10 (C) routes had been designated, some areas

within the motorized portions of the ODNRA were largely

inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10C to motorized cross-country travel and

allow motorized travel on the designated routes. Second,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 197 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Three alternatives (2, 4, and 5) analyze rezoning Management

Area 10C (designated routes only) to Management 10B (open)

in varying degrees. 

Guido, Kelly most of the trails in the 10(C) designated areas today are a 

result of encroachment of non-native species into the 

historically open riding areas

Areas of user-developed routes in MA 10 (C) occur in a

variety of vegetation in the ODNRA including plantations,

native vegetation and areas dominated by non-native

species. Please refer to Response #142 for a discussion on

existing vegetation in MA 10 (C) and its relationship to open

sand at the time the ODNRA was established.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 198 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Kelly the Forest Service simply does not have the resources to 

supervise and maintain these trails, a simple change in 

designation would solve many problems.

 

The Forest recognizes the need for upfront education and

enforcement of the designated routes decision to inform OHV

riders of routes open to motor vehicle use. Enforcement of the

trail system will be improved through signage, unauthorized

route closure, and regular patrols. Public compliance is

expected to increase with the formal designation of a more

understandable trail system connecting OHV riders to

beaches, open sand areas, and designated sand camps. Trail

operation and maintenance will be funded through Forest

Service appropriated funds, recreation fee revenues

generated in the Oregon Dunes NRA, and partnership funds

from the Oregon Parks and Recreation ATV grant

program. Cooperative law enforcement will continue to

address public safety issues. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 199 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Kelly change would be to change the 10(C) areas to 10(B) 

designation, “open riding” except for the bonafide wetlands.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Guido, Kelly What limited other maintenance that might be required could 

be achieved by turning the day-to-day operation over to each 

respective County Parks departments, who in turn would form 

a public/private cooperative effort between the county and 

clubs, organizations, and other interested citizens.

Land exchanges are outside the scope of this project.

Guido, Kelly 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 200 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The E.I.S. has not addressed the fact that of the 28,900 acres 

in the ODNRA that Congress designated “to provide for the 

public outdoor recreation use” only 11,435 remain open to 

ATV use, which is contrary to Congress’ original intent.[...]

Also, not mentioned is in the original 1972 Congressional Act, 

an “Advisory Council” was called for but to my knowledge was 

not implemented, nor does it exist today.

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 201 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

7. Secretary of Agriculture Regulation 36 CFR 295.6 -

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 202 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 203 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 204 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 205 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Guido, Kelly Our family has been riding at the dunes for generations and 

we prefer riding “trails” as opposed to the large “open” dunes.

Alternatives 2, 4, Modified 4 and 5 propose reallocations to

provide trail riding opportunities.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Haire, Tonya Because so many people ride the dunes, you should be 

opening up these areas not closing off more riding trails. 

Making the area smaller will be opportunities for more 

accidents.[...]Please do not close our trails and make our 

riding areas smaller!!!!

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Haire, Tonya Economic impacts are sufficiently examined in the DEIS and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 206 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The impact on the local economy will suffer if people find the 

area too small and too dangerous to continue riding.

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 207 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Hampton, Konagher I prefer to ride in all the trails over the open dunes. My family 

goes all season long and the main purpose we take the time 

to go is for the trails with the hill climbs and tight corners is 

the only reason. I feel anyone would go to the dunes except 

for racing Banshee Hill is talked about all the time and is my 

favorite trail. I continue to visit Winchester simply because of 

banshee hill.

This project would not affect existing areas managed as open

riding. Alternatives 2, 4, Modified 4 and 5 would increase

acreage managed as open riding. Alternatives 2, 4, Modififed

4 and 5 also propose that Banshee Hill be reallocated to open

riding. 

Hanlin, John we feel our concerns and input involving the closure of public 

lands should be heard and considered in this planning 

process. We have yet to be contacted and involved in any 

discussions or planning relating to the ODNRA Management 

Area 10 (C) Designated Routes Project.

The Forest followed laws, policies and regulations in soliciting

input for this project. The Siuslaw National Forest began

seeking information from the public in regard to the

Designated Routes project in 2009, when the Forest hired an

independent contractor to assemble and facilitate a working

group of individuals with varied interests in the Oregon Dunes.

In 2010, this working group provided ideas regarding a system

of designated trails and open riding areas that they believed

would meet the 1994 Dunes Plan. The results of their work

was posted to the Forest website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 208 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 130 comments on the DEIS.

Hanlin, John There are substantial economic impacts that would occur, but 

more importantly are the public safety threats that additional 

riding area closures would create.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 209 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Hanlin, John There are many public safety issues that need to be 

accurately shared and discussed. As a cooperating agency we 

request the opportunity to be involved in coordinated planning 

of any closures of the ODNRA.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 210 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hanna, Bruce In 1972; Congress established the ODNRA, recognizing that 

Oregon's landscape provides unique

recreational opportunities for families. Of the 28,900 acres 

originally dedicated to this area, more than half have now 

been closed to OHV use. The current DEIS runs counter to the 

intent of Congress when it established the ODNRA as a 

primarily open riding area "to provide for the public outdoor 

recreation use and enjoyment." This intent rings true today, 

but this proposal runs counter to it.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 211 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 212 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 213 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 214 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Hanna, Bruce consider the economic impact of this proposal. OHV activity in 

the Dunes is a $270 million industry. Further restrictions will 

only serve to reduce that number, the impact of which could 

be enormous in a part of the nation already experiencing 

severe economic depression.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 215 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 216 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hanna, Bruce Safety and environmental concerns in the ODNRA are of 

course critical.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Hanna, Bruce In the future, I hope there is greater coordination between 

the USFS and local communities in

identifying appropriate and effective solutions.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Harms, Sandy 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 217 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

believe that OHV recreation has already been "minimized" 

enough by previous NEPA decisions.[...]In 1972, 

approximately 28,000 acres were open for legal OHV use. 

After implementation of the 1979 ODRNA Management Plan, 

the acreage available for OHV use was reduced, by about 

47%, down to 15,000 acres. When the 1994 ODNRA 

Management Plan was adopted, the acreage available for 

open riding was reduce d significantly to 5,930 acres.[...]

Between 1972 and 2011, the acreage available for open OHV 

use has been reduced from 28,000 acres down to just below 

6,000 acres. Just 20 percent of the NRA is available for legal 

OHV use today.

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 218 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 219 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 220 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 221 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Harms, Sandy Please withdraw the current DEIS and associated public 

comment period, conduct supplemental analysis and issue a 

supplemental EIS to include and seek input on additional 

alternatives to those presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 222 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Harms, Sandy The Forest Service should create a new or modified planning 

process with alternatives that might help the agency and the 

public to meet the current purpose and needs of the resource 

and community.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 223 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 224 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Harms, Sandy We also own a vacation rental on Ten Mile Lake that is 

frequently rented to dune riders. Please do not limit the 

amount of rideable acres to the public, as it will negatively 

impact our income through our rental,

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 225 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 226 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Harms, Sandy cut down on my family's recreation Alternatives 2, 4, Modified 4 and 5 propose reallocations to

provide trail riding opportunities.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Harris, Tom The net loss of usable acres from the 1972 figure of 28000 

acres to the 1994 Management

Plan which shows less than 6000 acres available is just not 

acceptable. This loss in an

OHV Area, particularly on a surface that describes the ultimate 

in sustainability is hardly

a step in the right direction.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 227 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations: • South Jetty Big Dune area. • South Jetty parking lot #1. • Siltcoos Beach parking lot. • Tenmile Creek parking lot.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 228 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 229 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 230 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 231 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 232 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Harris, Tom It has been pointed out by concerned

organizations that the DEIS based on the 1994 Dunes Plan 

was created without a legally

required input from an NRA Advisory Council. The local 

counties have not affectively

participated in this EIS or the 1994 Dunes Plan.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Harris, Tom The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 233 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

we ask that you withdraw the current DEIS

and the associated public comment period, conduct 

supplemental analysis and issue a

supplemental EIS to include and seek input on additional 

alternatives to those presented

in the DEIS.

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 234 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Hart, Tyrrell Please withdraw the current DEIS and associated public 

comment period

and conduct a supplemental analysis and lets get a new DEIS 

that

includes the input of the true users of the ODRNA and then 

manage the

area for its best use.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 235 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 236 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger Throughout the DEIS, misinformation is being treated. as fact. 

This is the use, over

175 times, of the term "user created trails'; and "user created. 

routes". This

term is just plain false. The vast majonty otthese trails and 

routes were -NOT user created but rather created by the 

natural blowing of sand, into vegetated

areas (both native and non-native), that in turn are ridden on 

by OHVs. By using

the "user-created" term, gives the impression that somehow 

users have cleared

vegetation, and dumped sand to create these "trails" and 

"routes". That as you

know, is virtually impossible, and patently false. The sand is 

ever changing each

season. This is so different than "trails" in a regular forest, 

where once a trail is

established, it is there for a long time. Trails in the ODNRA are 

dynamic and

change over time, not from users creating them, but rather 

mother nature blowing

sand into different areas. Also many of the "trails" are located 

in previously open

riding areas, that because of encroachment of nonnative/invasive species, have

grown up around "trails" that historically have b~en ridden 

on. The terms: "user

created trails" and "user created" routes, should be eliminated 

from the E.I.S. That

would certainly lead to a different conclusion by anyone 

reading it.[...]In addition, the amount of "trails" in the 10 C 

areas is vastly underreported. The

study says there are 13 5 miles of trails, when in actuality 

The term "user-created" trails defines trails that have not been

designated, numbered or mapped by the Forest Service. It is

true that many of these trails existed prior to the 1979 or the

1994 Dunes Plans. However, both Plans envisioned a

designated route system through vegetated areas. This vision

was not fulfilled. With the 2005 Travel Management Rule,

forests were directed to designate roads, trails and areas that

are open to motorized travel. This was a change from forests

being open to motorized travel unless designated

closed. Management Area 10C was designated closed except

for designated routes in the 1994 Dunes Plan, however this

was not fully implemented. It was recognized during the

development of the Siuslaw Travel Management

Environmental Assessment that due to the fact that trails were

not designated, many areas on the ODNRA were not legally

accessible. This FEIS attempts to bring the ODNRA into

compliance with the 2005 Travel Management Rule by

designating trails and open areas within Management Area

10C and to make the designations comprehensive and

understandable that can be effectively managed and

maintained.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 237 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

there are 4 or 5 times that

amount, which the study proposes to close.

Hartman, Roger These "trails" not only have been

ridden on for DECADES but are an important ingredient in the 

overall riding

experience of families. Trails, rather than the large "open" 

dunes give families

an opportunity to all ride together when there are young kids 

and novice riders

who are not able to ride the steeper dunes. The trail systems 

should be

EXPANDED, rather than curtailed through closures. This was 

not even addressed

in the plan.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Hartman, Roger It appears that this study relies on regulations/policies that 

are intended for general

forests, and not congressionally created Recreation Areas. 

Being a totally sand based area, makes

it quite different than the general forests. While the FS 

assumes that all rules/regulations that

apply to the general forests, apply to this RECREATION AREA, 

it would in many cases be

diametrically opposed Congress' original intent for this area.

The 1994 Dunes Plan directs management of the Oregon

Dunes NRA (ODNRA). In 1994, the Forest Service adopted

the Management Plan for the ODNRA which amended the

Siuslaw National Forest Plan. The Dunes Plan directs that MA

10 (C) be managed to permit motorized vehicles on

designated routes only.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 238 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger Originally, almost 100% of the total of 28,900 acres of the 

ODNRA was open to OHVs. After set asides for various 

purposes, the amount was supposed to be 46-47%, open to 

OHVs, which would be app. 13,300 acres This would be 

acceptable, but the reality is that OHVs are only allowed on 

less than 7,000 acres of the original 28,900 acres that 

Congress set aside for RECREATION. Counting any 10 C areas 

as being open to OHVs is wrong. The corridors/designated 

routes are already accounted for in 10 D. The only open areas 

for OHVs are 10 Band 10 D, totaling

6,980 acres. This does not comply with Congressional intent 

and this should have been considered in the latest decisions 

for this particular study, but was not.

The DEIS does not describe 46% of the ODNRA as open to

cross country OHV travel.

The DEIS and the FEIS state, "In 1994, the current Dunes

Plan was adopted, zoning 46% of the ODNRA as open to

OHV use to various degrees. This number includes MA 10(B),

where open riding is permitted, as well as Management Areas

10(C), 10(G), and 10(L), where OHV use is permitted on

designated routes only." (FEIS, Chapter 3, Recreation,

Cumulative Effects. The 11 management areas and their

primary emphasis and associated acres were provided in the

DEIS, Chapter 1, Background, p. 8 and can be found in the

FEIS Chapter 1, Background. Management area acreage

percentages that are included in the 46% that allow OHV use

to varying degrees are as follows; MA 10(B) Off-Road Vehicle

Open (21%), MA 10(C) ORV on Designated Routes (15%), 

MA 10(G) Wetlands Emphasis (9%) and MA 10(L) Noise

Control Buffer (1%).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 239 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger The DEIS does not consider viable alternatives in detail. One 

of these alternatives would be the EXPANSION of trail 

systems, which would be complying with the directive by 

Congress of DEVELOPMENT of the ODNRA as part of the FS 

responsibility.

No specific number of alternatives is required (42 USC 4332,

102(c)(iii) and E, 36 CFR 220.b(2)), but rather alternatives are

driven by cause-and-effect-statements. The range of

reasonable alternatives includes both alternatives that warrant

detailed analysis and alternatives that are considered, but

eliminated from detailed study. The Forest Service developed

five alternatives, including the No Action alternative, in

response to the issues raised by the public, by other agencies

and internally. Two additional alternatives were considered

but eliminated from detailed study. Alternatives provide

different ways to fulfill the purpose and need and address

unresolved conflicts related to the proposed action. All

alternatives are discussed in chapter 2 of DEIS and FEIS,

including issues that drove the development of alternatives

and a table comparing alternatives. 

In response to comments on the DEIS, an additional

alternative, Modified 4 was developed. Including the No

Action Alternative, five alternatives to the proposed action

were developed. 

Hartman, Roger Another alternative that was not addressed is the possible reopening of the area between Spinreel and Winchester Bay. 

This entire area should not be closed. If some of it is in fact 

snowy plover area, than that area as well as any truly 

wetlands should be protected and the balance should be 

reopened to OHV s.

It is outside the scope of this analysis to rezone any areas not

within Management Area 10 (C).

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Oregon Dunes National

Recreation Area currently has about 34 miles of designated

trails and about 5,930 acres of designated areas for open

motorized travel. As the Siuslaw National Forest developed its

2009 Travel Management Plan, it became apparent that since

not all the MA 10 (C) routes had been designated, some areas

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 240 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

within the motorized portions of the ODNRA were largely

inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10C to motorized cross-country travel and

allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Three alternatives (2, 4, and 5) analyze rezoning Management

Area 10C (designated routes only) to Management 10B (open)

in varying degrees. 

Hartman, Roger The effect of the encroachment of non-native/invasive species 

vegetation on the areas open to OHV s, was not addressed, or 

considered. This is a huge impact on the available acres of 

riding for OHV s. Aerial photos and maps certainly show that 

much of the once open dunes which were available to OHV s 

for riding, have disappeared as a result of this encroachment 

of non-native/invasive species. Because of a lack of resources, 

the Forest Service has been unable to stop this encroachment. 

That does not alter the intent of the Congress for the use of 

the 28,900 acres set aside for RECREATION.

H.R. 8763, established the Oregon Dunes National Recreation

Area in order "to provide for public outdoor recreation use and

enjoyment of certain ocean shorelines and dunes, forested

areas, fresh water lakes, and recreational facilities..." Please

refer to Response #142 for a discussion of open dunes in

1972, and 1979 when the first Dunes Plan was released as

compared to current conditions. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 241 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger The best plan of action should be to either redesignate all 10 

C areas to 10 B (open riding) which would solve all of the 

controversy, or alternatively totally abandon this current 

document.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Hartman, Roger Throughout the DEIS, misinformation is being treated as fact. 

This is the use, over

175 times, of the term "user created trails'and "user created 

routes". This

term is just plain false. The vast majonty otthese trails and 

routes were NOT user created but rather created by the 

natural blowing of sand, into vegatated

areas (both native and non-native), that in turn are ridden on 

by OHV's. By using

the "user-created" term, gives the impression that somehow 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 242 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

users have cleared

vegetation, and dumped sand to create these "trails" and 

"routes". That as you

know, is virtually impossible, and patently false. The sand is 

ever changing each

season. This is so different than "trails" in a regular forest, 

where once a trail is

established, it is there for a long time. Trails in the ODNRA are 

dynamic and

change over time, not from users creating them, but rather 

mother nature blowing

sand into different areas. Also many of the "trails" are located 

in previously open

riding areas, that because of encroachment of nonnative/invasive species, have

grown up around "trails" that historically have been ridden on. 

The terms: "user

created trails" and "user created" routes", should be 

eliminated from the E.I.S. That

would certainly lead to a different conclusion by anyone 

reading it.[...]In addition, the amount of"trails" in the 10 C 

areas is vastly underreported. The

study says there are 13 5 miles of trails, when in actuality 

there are 4 or 5 times that

amount, which the study proposes to close.

The term "user-created" trails defines trails that have not been

designated, numbered or mapped by the Forest Service. It is

true that many of these trails existed prior to the 1979 or the

1994 Dunes Plans. However, both Plans envisioned a

designated route system through vegetated areas. This vision

was not fulfilled. With the 2005 Travel Management Rule,

forests were directed to designate roads, trails and areas that

are open to motorized travel. This was a change from forests

being open to motorized travel unless designated

closed. Management Area 10C was designated closed except

for designated routes in the 1994 Dunes Plan, however this

was not fully implemented. It was recognized during the

development of the Siuslaw Travel Management

Environmental Assessment that due to the fact that trails were

not designated, many areas on the ODNRA were not legally

accessible. This FEIS attempts to bring the ODNRA into

compliance with the 2005 Travel Management Rule by

designating trails and open areas within Management Area

10C and to make the designations comprehensive and

understandable that can be effectively managed and

maintained.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 243 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger These "trails" not only have been

ridden on for DECADES but are an important ingredient in the 

overall riding

experience of families. Trails, rather than the large "open" 

dunes give families

an opportunity to all ride together when there are young kids 

and novice riders

who are not able to ride the steeper dunes. The trail systems 

should be

EXPANDED, rather than curtailed through closures. This was 

not even addressed

in the plan.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Hartman, Roger It appears that this study relies on regulations/policies that 

are intended for general

forests, and not congressionally created Recreation Areas. 

Being a totally sand

based area, makes it quite different than the general forests. 

While the FS assumes

that all rules/regulations that apply to the general forests, 

apply to this

RECREATION AREA, it would in many cases be diametrically 

opposed

Congress' original intent for this area.

The 1994 Dunes Plan directs management of the Oregon

Dunes NRA (ODNRA). In 1994, the Forest Service adopted

the Management Plan for the ODNRA which amended the

Siuslaw National Forest Plan. The Dunes Plan directs that MA

10 (C) be managed to permit motorized vehicles on

designated routes only.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 244 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger Originally, almost 100% of the total of 28,900 acres of the 

ODNRA was open to

OHV s. After set asides for various purposes, the amount was 

supposed to be 46-

47%, open to OHVs, which would be app. 13,300 acres This 

would be acceptable,

but the reality is that OHVs are only allowed on less than 

7,000 acres of the original

28,900 acres that Congress set aside for RECREATION. 

Counting any 10 C areas

as being open to OHV s is wrong. The corridors/designated 

routes are already

accounted for in 10 D. The only open areas for OHVs are 10 

Band 10 D, totaling

6,980 acres. This does not comply with Congressional intent 

and this should have

been considered in the latest decisions for this particular 

study, but was not.

The DEIS does not describe 46% of the ODNRA as open to

cross country OHV travel.

The DEIS and the FEIS state, "In 1994, the current Dunes

Plan was adopted, zoning 46% of the ODNRA as open to

OHV use to various degrees. This number includes MA 10(B),

where open riding is permitted, as well as Management Areas

10(C), 10(G), and 10(L), where OHV use is permitted on

designated routes only." (FEIS, Chapter 3, Recreation,

Cumulative Effects. The 11 management areas and their

primary emphasis and associated acres were provided in the

DEIS, Chapter 1, Background, p. 8 and can be found in the

FEIS Chapter 1, Background. Management area acreage

percentages that are included in the 46% that allow OHV use

to varying degrees are as follows; MA 10(B) Off-Road Vehicle

Open (21%), MA 10(C) ORV on Designated Routes (15%), 

MA 10(G) Wetlands Emphasis (9%) and MA 10(L) Noise

Control Buffer (1%).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 245 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger The DEIS does not consider viable alternatives in detail. One 

of these alternatives

would be the EXPANSION of trail systems, which would be 

complying with the

directive by Congress of DEVELOPMENT of the ODNRA as part 

of the FS

responsibility.

No specific number of alternatives is required (42 USC 4332,

102(c)(iii) and E, 36 CFR 220.b(2)), but rather alternatives are

driven by cause-and-effect-statements. The range of

reasonable alternatives includes both alternatives that warrant

detailed analysis and alternatives that are considered, but

eliminated from detailed study. The Forest Service developed

five alternatives, including the No Action alternative, in

response to the issues raised by the public, by other agencies

and internally. Two additional alternatives were considered

but eliminated from detailed study. Alternatives provide

different ways to fulfill the purpose and need and address

unresolved conflicts related to the proposed action. All

alternatives are discussed in chapter 2 of DEIS and FEIS,

including issues that drove the development of alternatives

and a table comparing alternatives. 

In response to comments on the DEIS, an additional

alternative, Modified 4 was developed. Including the No

Action Alternative, five alternatives to the proposed action

were developed. 

Hartman, Roger Another alternative that was not addressed is the possible reopening of the area

between Spinreel and Winchester Bay. This entire area should 

not be closed. If

some of it is in fact snowy plover area, than that area as well 

as any truly wetlands

should be protected and the balance should be reopened to 

OHV s.

It is outside the scope of this analysis to rezone any areas not

within Management Area 10 (C).

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Oregon Dunes National

Recreation Area currently has about 34 miles of designated

trails and about 5,930 acres of designated areas for open

motorized travel. As the Siuslaw National Forest developed its

2009 Travel Management Plan, it became apparent that since

not all the MA 10 (C) routes had been designated, some areas

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 246 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

within the motorized portions of the ODNRA were largely

inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10C to motorized cross-country travel and

allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Three alternatives (2, 4, and 5) analyze rezoning Management

Area 10C (designated routes only) to Management 10B (open)

in varying degrees. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 247 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger The effect of the encroachment of non-native/invasive species 

vegetation on the

areas open to OHV s, was not addressed, or considered. This 

is a huge impact

on the available acres of riding for OHV s. Aerial photos and 

maps certainly show

that much of the once open dunes which were available to 

OHV s for riding, have

disappeared as a result of this encroachment of nonnative/invasive species. Because

of a lack of resources, the Forest Service has been unable to 

stop this encroachment.

That does not alter the intent of the Congress for the use of 

the 28,900 acres set

aside for RECREATION.

H.R. 8763, established the Oregon Dunes National Recreation

Area in order "to provide for public outdoor recreation use and

enjoyment of certain ocean shorelines and dunes, forested

areas, fresh water lakes, and recreational facilities..." Please

refer to Response #142 for a discussion of open dunes in

1972, and 1979 when the first Dunes Plan was released as

compared to current conditions. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 248 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hartman, Roger The best plan

of action should be to either redesignate all 10 C areas to 10 

B (open riding) which

would solve all of the controversy, or alternatively totally 

abandon this current

document.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Hatten, Chris I would be quite happy if we could just keep out OHV users 

from there and other OHV free areas in the ODNRA so others 

can also enjoy the solitude of this remarkable areas, without 

new illegal OHV trails going where there was once none, 

which now seem to spider web across many new areas.

No changes to allow OHVS in areas where they are prohibited

are proposed. Approximately 54% of the ODNRA is closed to

motorized recreation, providing opportunities for nonmotorized recreational use. Of the 46% of the ODNRA

managed for motorized use to some degree, this project

addresses the 4,455 acres in Management Area 10 (C)

wherein motorized use is permitted on designated routes.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 249 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hawkins, Craig I am opposed to any more closures to the ODNRA On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Hawkins, Craig I am also a life long disabled individual whose only means of 

getting to these areas is with the use of an OHV/ATV. I can 

not walk and I can not ride a horse. With the closing of these 

trails now in question and the recent closing of the lakes that 

I have been going to on a regular basis that have a very 

important and spiritual meaning to me, I can't help but feel 

my rights are being violated. I also know of several other 

disabled individuals that this will effect.

A basic aspect of the route designation, as part of travel

management, is to identify routes and areas where motor

vehicle use is appropriate for all members of the

public. Allowing exemptions to route designations for persons

with disabilities would not be consistent with the resource

protection and other management objectives of route

designations. Restrictions on motor vehicle use that are

applied consistently to everyone are not discriminatory.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 250 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hervig, Suzanne Please reconsider your proposals[...]riding on the open dunes 

while fun for many, isn't the one thing I enjoy the most. I do, 

however, love riding on the trails.[...]if you close the trails you 

will be cutting off a vital part of the sand dune riding 

experience.[...]I have also heard that our riding is helping to 

keep the invasive sand grass from spreading.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Hickenbottom, Aaron Closing more riding areas is not the thing to do. More and 

more people are riding 4

wheelers, Razors, sand buggies, etc. We need MORE space to 

ride, not less! Taking

these areas away are a mistake.[...]Please! Do not close any 

trails or riding areas.

Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Hickenbottom, Aaron Closing more riding areas is not the thing to do. More and 

more people are riding 4

wheelers, Razors, sand buggies, etc. We need MORE space to 

ride, not less! Taking

these areas away are a mistake.[...]Please! Do not close any 

trails or riding areas.

Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 251 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Higgins, Mike - Native vegetation and wetlands must be protected and 

safeguarded from motorized recreation.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Hine, Gerry Over the past 5+ years, we have noticed the sound buffer 

closure signage (posts & signs) have made a yearly migration 

from east towards the west. Every year the sign posts are 

relocated anywhere from 50 feet to over a 100 yards. Most 

notable is the closure line to the west of the Woahink trailer & 

RV Park. Also, the closure line along the SE corner (west of 

North Beach Bay). Many times we have seen old buffer signs 

uncovered by sand (old sign), and a new sign a great distance 

to the west. It seems where its legal to ride one summer, the 

next its in a "closure" noise buffer. No consistency.

Thank you for your comment, your concerns have been

shared with our OHV managers.

Hine, Gerry Proposal 5 is the only one close to being acceptable. However, 

if adopted, Proposal 5 needs some revision as well. First, the 

trail system which exists between South Jetty road and Goose 

Pasture OHV Trail need to be "opened" (currently used, but 

designated closed). These trails offer kids & less experience 

riders a safe place to ride while campingin these designated 

areas. Second, the trail system to the East of the South - 

"Soutn Jetty OHV Trail," should be opened 9currently used but 

designated closed) most of these trails have been in use for 

the last 25+ years.

In response to this comment, the planning team for this

project visited the area of trails between South Jetty Road

and the Goose Pasture designated route. This area has been

added as a proposed reallocation to open riding in Modified

Alternative 4. This would increase the A3 reallocation from 6

acres to approximately 28 acres. The trails east of South Jetty

designated route are proposed for reallocation to open riding

in Alternative 5.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 252 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Clifton put a stop to this action.[...]closure of riding area/trails at the 

Oregon Dunes National Recreation Area. This would be a 

terrible mistake. And I would greatly appreciate your support 

in helping to

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Hinton, Clifton The financial impact alone would be devastating. Not to 

mention the negative impact on families across the United 

States as well as from other countries.[...]I don’t believe the 

communities surrounding the Oregon Dune Recreation Area 

can survive another negative impact on their livelihoods. And 

reducing the riding area will most definitely have a negative 

effect.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 253 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 254 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Clifton I respectfully request a modified alternative 5 in which the 

Forest Service review all 10c areas for invasive species.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 255 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Clifton I request that you create an Advisory Committee to take into 

account the public and business views of those involved, 

including those many users from other states.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Hinton, Clifton I personally would like to see more trails opened for use Thank you for your comment.

Hinton, Clifton Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 256 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The financial impact alone would be devastating.[...]I don’t 

believe the communities surrounding the Oregon Dune 

Recreation Area can survive another negative impact on their 

livelihoods. And reducing the riding area will most definitely 

have a negative effect.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 257 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Hinton, Clifton I respectfully request a modified alternative #5 in which the 

Siuslaw National Forest Service review all 10c areas for 

invasive species.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 258 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Clifton In addition, I request that an Advisory Committee be formed 

to take into account the public and business views of those 

involved, including those many users from other states.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Hinton, Clifton An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 259 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

would like to see more trails opened for use, more 

enforcement/patrol on the dune area, and a better way of 

outlining open & closed areas. I’m sure there are several 

organizations and individuals that are willing to assist in 

building/maintaining trails in this area. Possibly using an 

Adopt-A-Trail type system.

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 260 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 261 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Clifton regards to the possible closure of riding area/trails at the 

Oregon Dunes National Recreation Area. This would be a 

terrible mistake.

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Hinton, Clifton possible closure of riding area/trails at the Oregon Dunes 

National Recreation Area. This would be a terrible mistake. 

And I would greatly appreciate your support in helping to put 

a stop to this action.

Please refer to Response #47.

Hinton, Clifton The financial impact alone would be devastating.[...]I don’t 

believe the communities surrounding the Oregon Dune 

Recreation Area can survive another negative impact on their 

livelihoods. And reducing the riding area will most definitely

have a negative effect.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 262 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 263 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Clifton I respectfully request a modified alternative #5 in which the 

Siuslaw National Forest Service review all 10c areas for 

invasive species.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 264 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Clifton In addition, I request that an Advisory Committee be formed 

to take into account the public and business views of those 

involved, including those many users from other states.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Hinton, Clifton An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 265 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

would like to see more trails opened for use, more 

enforcement/patrol on the dune area, and a better way of 

outlining open & closed areas. I’m sure there are several 

organizations and individuals that are willing to assist in 

building/maintaining trails in this area. Possibly using an 

Adopt-A-Trail type system.

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 266 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Hinton, Kathy keeping the trails open will keep the many thousands of 

dollars coming as income to the coastal communities

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 267 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 268 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Kathy The concern that over the years, riders have created 

additional trails through the vegetated section does not 

constitute a negative impact in my opinion. It is my 

understanding the “grass” on the dunes is not native to the 

U.S. and is classified as an invasive species. That is a negative 

impact!.

The 1994 Dunes Plan directs that MA 10 (C) be managed to

"protect existing vegetated areas while providing controlled

opportunities for ORV riding and travel on designated

routes" (Dunes Plan, p.III-36). The Dunes Plan directs

managment of MA 10 (C), and therefore, vegetated areas will

be protected and motorized vehicles will only be permitted on

designated routes within MA 10 (C). 

Areas of predominantly non-native vegetation such as

European beachgrass and Scotts broom are proposed to be

reallocated to open riding in alternatives 2, 4, Modified 4 and

5. The intent is of this project is not to protect non-native

vegetation. However, areas of non-native vegetation near

residential areas and areas of non-motorized recreation areas

were not proposed for reallocation to open riding in order to

reduce the impact of noise, thereby reducing user-conflicts.

Hinton, Kathy I believe there are at least 3 invasive species that are 

currently consuming the dunes. That is a negative impact!

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 269 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Kathy I respectfully request a modified alternative #5 in which the 

Siuslaw National Forest Service review all 10c areas for 

invasive species.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 270 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hinton, Kathy I would also request that an Advisory Committee be formed to 

take into account the public and business views of those 

affected by these proposed closures.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 271 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Hoover, Greg I do not agree with any of the proposals[...]the supposed 

trails that are referred to were not there 20 or some even 10 

years ago, they were at one time open riding area and when 

the invasive species started to cover up the open riding area 

and what you refer to a user created trails were just a means 

to ride in the dunes.[...]During these hard economic times 

when we are struggling to stay afloat I suggest that the 

Forest Service not close any more riding area and work with 

existing groups to better manage the ODNRA ,by eradicating 

the invasive plants that are destroying one of the most unique 

riding areas that exist.

Without question, non-native species have advanced into

formerly open areas of sand. However, when comparing

existing vegetation in 1979 aerial photos of the riding areas, to

the current boundaries of Management Area 10 (C), the

footprint of vegetated areas is very similar, with the consistent

exception being the eastward advancement of vegetation in

the deflation plain. 

The 1979 Dunes Plan called for OHVs to be restricted in

vegetated areas. The 1994 Plan calls for the same

restrictions. Those vegetated areas, while more heavily

vegetated now that in 1979 are similar in terms of total

acreage. Designated routes, as directed by the 1994 Dunes

Plan, should connect open riding areas as well as connect

open riding areas to the beach. The age of trail is not a

consideration in proposing designation. Instead, by law, a

designated trail must meet the objectives of the 1994 Dunes

Plan.

Hoover, Greg The North Jetty, Sparrow Park area is not even addressed in 

the EIS or proposals, yet it is the only place in the middle 

riding area where our guests can ride on the beach and on 

the open dunes along the river.

Beaches are not under the jurisdiction of the Siuslaw National

Forest, but are managed by the Oregon Parks and Recreation

Department. 

Hoover, Greg The areas already designated for non motorized use are 

frequently empty even in the summer months, has this been 

monitored?

Areas outside of Managment Area 10 (C), including areas

managed for non-motorized recreation, are outside the scope

of this project. 

Hoover, Greg I will also state that the OHV community spends far more 

money to recreate in the area than the non motorized 

community, to even consider that backfill will be monetarily 

even, is bad economics.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 272 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 273 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Huckaby, Ryan The agency in Zone 10 (C) attempts to create the illusion that 

4,455 acres of designated routes are available for OHV use.

Managment Area 10 (C) consists of 4,455 acres wherein

OHVs are permitted on designated routes only. The

managment of MA 10 (C) is described under "Background" in

Chapter 1.

Jarvis, Donald We enjoy using the smaller trails between the foredunes and 

the coast guard road at Florence.

This refers to A2, an area proposed for reallocation to open

riding in Alternatives 2, 4, Modified 4 and 5.

Jeffers, Rob I would like more area's opened and the invasive species 

removed for good, the main reason I go to the dunes is for 

the trail riding, if more trails are closed and the area's limited 

farther the more accidents there are going to be.

Dune restoration, trail riding and safety are addressed in

response numbers 3, 71 and and 17 respectively.

Jeffers, Rob If the amount of trails to ride are reduced it will create unsafe 

conditions, wrecks and even worse death.[...]I have three 

young kids that ride with me and am concerned if the trails 

are reduced it would create unsafe conditions for them to ride

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 274 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Jeffers, Rob we need to focus on reclaiming our dunes from beach grass 

and plant native species not invasive species that spreads 

everywhere and claims everything in its path.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Johnson, Ladd The exhisting trails are getting too crowded causing trail 

errosion and unsafe conditions with head on collisions. Setting 

land aside for OHV recreation is a responsible thing to do.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 275 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Johnson, Phillip We therefore support Alternative 4, the preferred alternative, 

which

allows a little more area for OHV riding in areas dominated by

non-native species which do not contain sensitive species, and 

appears

to include the best choices for designated routes. We support 

this

alternative with two major caveats, and a small number of 

proposed

modifications.

Thank you for your comment.

Johnson, Phillip The first caveat concerns enforcement. The trade-off of 

allowing more

riding area while closing undesignated routes is only valid for 

the

public if the undesignated routes are actually closed. This 

alternative

must be backed with a vigorous, effective enforcement plan, 

involving

signage and education, to be sure, but utilizing fencing where

violations persist, devoting personnel to on-the-ground 

enforcement,

increasing fines if necessary, and banning repeat violators 

entirely

from riding anywhere in the Oregon Dunes NRA.[...]The 

Forest Service will

not be operating in good faith if it does not take whatever 

steps are

necessary to enforce closure of undesignated routes.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 276 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 277 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

approach to enforcement and insurance that

violations are handed in a consistent manner.

Johnson, Phillip minor modifications of the preferred alternative could help

to reduce noise levels to a degree (see below).[...]*More 

could be done to reduce noise impacts in the north riding area

along South Jetty Road and in particular by prohibiting OHV 

use of the

dune immediately adjacent to the South Jetty Staging Area.

[...]Instead, what we would say is that the Forest Service

has not adequately enforced maximum noise levels to date, 

and that as a

matter of good faith in managing the Oregon Dunes for all its 

visitors

and for its natural values in the future, the agency should 

devise a

supplementary noise enforcement plans that will both enforce 

regulations

against individual violators and will potentially reduce overall 

vehicle

use or even declare a moratorium in a particular area of the 

collective

impact of OHV use persistently exceed maximum allowable 

levels.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Johnson, Phillip The northern portion of the A2 section, from Goose Prairie up 

to the

non-motorized recreation area, should not be open to riding 

on the

foredune. This will particularly degrade the experience of 

other

visitors to the area, and increase noise impacts nearby.

The northern portion of the proposed A2 reallocation would tie

into an existing designated route along the southern edge of

the South Jetty Road. OHV use of the designated route

accessing the beach from the Goose Pasture staging area will

continue just south, and visible from the South Jetty Road.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 278 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Johnson, Phillip Sand camps near the Lagoon Campground and Trail should be 

moved to

reduce likely impacts of persisting illegal use of nondesignated areas

on those seeking other types of recreational experiences and 

to

facilitate enforcement. Alternatively, the camps could be 

eliminated.

Relocating sand camps is outside of the scope of this project.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA.

The designated sand camps along the Incinerator designated

route are popular sites that are occupied nearly every summer

weekend. The sites provide a sand camping experience that

has become popular with families with small children because

those sites are isolated from the traffic and activity occurring

on open dunes. User-developed routes in the Incinerator area

are proposed to be enforced as closed in all alternatives. 

Johnson, Phillip All undesignated routes through areas of natural vegetation 

on the east

side of the middle riding area should be eliminated and this 

should be

vigorously enforced.

No alternatives propose designated routes or reallocations of

MA 10 (C) to MA (B) open riding on the eastern side of the

Middle Riding Area. Areas not open to motorized vehicles will

be enforced as closed.

Johnson, Phillip A wider buffer between legal riding areas and the natural 

areas

associated with Beale Lake should be created, allowing for the

likelihood that there will be some spillover beyond the limits of 

the

open area.

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Jones, Carole Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 279 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

this new plan with destroy the Forest Services’ ability to 

manage the land along with to further cripple economically 

the communities that service the Oregon Dunes.[...]As an out 

of state resident I will not go to the Oregon Dunes and spend 

my thousands of dollars per year on multiple visits if the 

proposed areas’ are closed

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 280 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Jones, Carole With the multiple fold drop in enforcement funding the 

multiple fold increase in closed areas’ will not have one 1/10th 

the needed man power to enforce those closed areas’.[...]

Posting proper signs to show all the trail closures would be a 

terrible expense and never be done correctly

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 281 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 282 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Jones, Carole With the huge amount of closed trails proposed it will create 

bottlenecks at the little left trails

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Jones, Sandra I do not agree with proposed limitations to the Oregon Dunes 

with respect to off road vehicles.[...]I am now 63 years old 

and have personally witnessed the loss of open dune areas to 

acres and acres of dense vegetation.[...]Now, the area we 

hiked on - pure sand dune at the time - is part of a dense pine 

forest. Nearby, what was once a huge wetland where 

migratory birds could be seen in the fall, is now fields of low 

shrubs and brush where seasonal lakes and ponds have been 

marginalized over the past forty-plus years.[...]Rules that 

concentrate and reduce ridership rather than welcoming a 

degree of wear and tear on invasive vegetation is 

counterproductive.

Please refer to Response #3 for a discussion of Dune

Restoration, and to Response #30 for discussion regarding to

the impact of OHVs on reducing and eliminating invasive

species.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 283 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Karin Spady, Jay Vegetation and dune management should dovetail with 

recreation management as part of a coordinated strategy.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Karin Spady, Jay The purpose and need should have been broadened to 

address the legislative intent of the original National 

Recreation Area Act.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Karin Spady, Jay Please withdraw the current DEIS and associated public 

comment period, conduct supplemental analysis and issue a 

supplemental EIS to include and seek input on additional 

alternatives to those presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 284 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 285 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Karin Spady, Jay In short, the Oregon Dunes present a unique situation where 

active sand dunes should be a desired condition and 

encroachment of non-native vegetation is a "significant issue" 

that must be addressed.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 286 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Karin Spady, Jay The DEIS may be fatally flawed since it is based on the 1994 

Dunes Plan, which was created without legally required input 

from an NRA advisory council. Also, the 1994 Plan is well 

beyond its useful period of 10-15 years as identified within the 

plan. The plan also states that the Forest Supervisor shall 

review the plan every five years to determine if conditions or 

public demands have changed significantly.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective on June 10,

1977, in accordance with the provisions of the federal

Advisory Committee Act (FACA) of 1972 (Public Law 92-463).

The Dunes Plan was prepared according to Secretary of

Agriculture regulations (36 CFR 219) which are based on the

Forest and Rangeland Renewable Resources Planning Act

(R_A) as amended by the National Forest Management Act of

1976 (NFMA). The Dunes Plan was also developed in

accordance with regulations (40 CFR 1500) for implementing

the National Environmental Policy Act of 1969 (NEPA).

Karin Spady, Jay I believe that OHV recreation has already been "minimized" 

enough by previous NEPA decisions.[...]In 1972, 

approximately 28,000 acres were open for legal OHV use. 

After implementation of the 1979 ODRNA Management Plan, 

the acreage available for OHV use was reduced, by about 

47%, down to 15,000 acres. When the 1994 ODNRA 

Management Plan was adopted, the acreage available for 

open riding was reduced significantly to 5,930 acres.[...]

Between 1972 and 2011, the acreage available for open OHV 

use has been reduced from 28,000 acres down to just below 

6,000 acres. Just 20 percent of the NRA is available for legal 

OHV use today.[...]The DEIS continues, I believe, to wrongly 

fixate on restricting OHV access rather than a logical and 

more legally defensible focus on broader management issues.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 287 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 288 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 289 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 290 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 291 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Karin Spady, Jay The agency failed to coordinate with affected counties in this 

EIS and the 1994 Dunes Plan. I want to ensure the ODNRA is 

following administration directives and has actively considered 

designation of federal and non-federal cooperating agencies in 

the preparation of analyses and documentation required by 

the National Environmental Policy Act (NEPA). I also want to 

ensure that Federal agencies actively participate as 

cooperating agencies in other agency's NEPA processes

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Karin Spady, Jay The project should address active and effective vegetation 

management alternatives,

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Keele, Betty The residential

staging area from Joshua Lane is not appropriate for OHV use.

[...]Please continue keeping this area closed to OHV riding.

The Joshua Lane area was closed to motorized use in the

Travel Management Project (2009). 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 292 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Kettman, Chris One of my biggest concerns is the idea of reducing the size of 

the available space to be ridden in means we will have more 

people in less space. That is not going to make it safer for me 

or my family.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Kettman, Chris From a financial standpoint, to reduce the size of the dunes 

will be an impact to the local community and to many 

companies in the pacific northwest that support the sport.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 293 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Kettman, Chris Keep the dunes open, and if you can expand them, please do 

so.

Expanding open riding areas, MA 10 (B), is outside of the

scope of this project. The primary purpose of this project is to

designate routes and areas within MA 10 (C) of ODNRA,

wherein OHVs are permitted on designated routes only.

Kettman, Chris It will make it safer for everyone and likely cause us to return 

more each year because we will have more space to enjoy.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 294 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Kohler, Thad My family and I enjoy the trails more than the open dunes Alternatives 2, 4, Modified 4 and 5 propose reallocations to

provide trail riding opportunities.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Kohler, Thad view them as less crowded and safer areas for my children. Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 295 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Kohler, Thad I have very glad to see A2 added to be opened as this has 

never made since to me to close - knowing how and why the 

European grass came to be there.

Thank you for your comment.

Kohler, Thad In regards to area A12, there is a trail that goes to an 

overlook of cleawox lake that we have enjoyed since finding it 

the 1980's.

The area west of Cleawox is proposed for reallocation in

Alternative 5 and likely contains this trail. The area near

Cleawox is not proposed for reallocation in any other

alternatives in response to comments regarding user conflicts

in this area including the affect of OHV noise on nearby

residences and non-motorized recreation activity in and near

Cleawox Lake.

Kohler, Thad Of your proposals the best option would be Alternative 5. Thank you for your comment.

Kohler, Thad regarding User Defined Trails. I would submit if these trails 

encroach on a endangered species of plant or animal or 

disturb a sensitive wetland – then by all means it should be 

closed.[...]If they don’t however I believe they should remain 

open. Many User defined trails

The 1994 Dunes Plan directs the Forest to designate routes

that connect open riding areas, or connect an open riding area

to the beach. Not all user-developed routes within

Management Area 10 (C) meet this direction. Some areas of

MA 10 (C) are proposed for reallocation to open riding based

on several factors including the predominance of non-native

species such as Scotch broom and European beachgrass. For

a discussion of sensitive species please refer to the Botanical

Resources section of Chapter 3 in the DEIS and FEIS.

Kohler, Thad My point is educate us on where it is truly scientifically 

harmful to the environment for us to ride - post these areas 

closed and enforce them.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 296 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 297 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Kohler, Todd I support Alt 5. Thank you for your comment.

Kohler, Todd I enjoy loop on A12

That goes cleawox lake - turns around above lake.

Opening A2 zone makes great since to me.

Having designated routes is not workable solution.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 298 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Kohler, Todd Middle riding area - Forested fingers should be open. 

Continued use by OHVs on trails that cross the fingers is not

sustainable ecologically. In addition, these trails cannot

provide sustainable, long term, challenging recreational

opportunities sought after by the public. Historic use at

Banshee Hill confirms this. The initial route across Banshee

Hill was narrow and challenging requiring skills and equipment

only a few people possessed. As use continued and

equipment became more powerful, the trail widened, down

cut, undercut native vegetation, and became less steep with

the sand being pushed downhill. Ecologically, this has

undercut and killed additional native vegetation and provided

opportunities for new non-native vegetation growth. The

recreation experience is no longer as challenging and riders

have begun to develop new, more challenging trails adjacent

to Banshee Hill. Closing Banshee Hill is not practical. 

Designating trail opportunities on other fingers and

forthcoming associated challenging user created trails does

not simplify OHV management. This cyclic pattern of

continuously seeking challenging trails is not sustainable long

term. 

Kohler, Todd I enjoy the trails with my wife & kids - we think they are safer 

than the open dunes for our younger children.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 299 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Kohler, Todd I would like more trails open - similiar to Hatfield/MCC 

connecting OHV Areas.

Thank you for your comment.

Kohler, Todd I support opening all user defined trails that do not affect 

endangered or threatened species. i would close sensitive 

wetlands but leave open trails around them.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Krayer, Barry Users will see this as an ongoing effort to restrict OHV use 

based on the illegal 1994 Plan.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 300 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations: • South Jetty Big Dune area. • South Jetty parking lot #1. • Siltcoos Beach parking lot. • Tenmile Creek parking lot.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 301 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 302 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 303 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 304 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Krayer, Barry Vegetation and dune management should dovetail with 

recreation management as part of a coordinated strategy.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Krayer, Barry The agency has failed to coordinate with affected counties in 

this EIS and the 1994 Dunes Plan. I want to ensure the 

ODNRA is following administration directives and has actively 

considered designation of federal and non-federal cooperating 

agencies in the preparation of analyses and documentation 

required by the National Environmental Policy Act (NEPA). I 

also want to ensure that Federal agencies actively participate 

as cooperating agencies in other agency's NEPA processes.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 305 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Krayer, Barry Please withdraw the current DEIS and associated public 

comment period, conduct supplemental analysis and issue a 

supplemental EIS to include and seek input on additional 

alternatives to those presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 306 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Kuhl, Joel Fmiher limiting dune access and closing off areas will cause 

my investments in the area to dry up as there will be no 

reason for my family to travel to the coast.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 307 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 308 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Kuhl, Joel I would like to see a modified alternative 5 in which the Forest 

Service reviews all I Oc area for invasive species.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 309 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Kuhl, Joel I respectfully request that you create an Advisory Council will 

takes into account the public's viewpoint, such as my own. I 

would recommend you open more trail miles, and leave the 

open areas as they are.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Kuhl, Joel I have been following the potential for dune closures at the 

Oregon Dunes National Recreation Area. I cannot express 

what a catastrophic mistake this would be for Oregon as a 

travel destination, the local economy, and for my family.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 310 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 311 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Lacer, Jim We strongly support the alternative that leaves the most area 

open for riding while still providing necessary protection for 

the environment.

Thank you for your comment.

Lambert, Gary The economic contribution of OHV use is very important and 

reducing riding always hurts employment.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 312 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Lambert, Gary The timing of this project is suspect since a Forest revision is 

scheduled for 2014.

At one time the Siuslaw National Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 313 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Lambert, Gary The agency failed to coordinate with affected counties in this 

EIS and the 1994 Dunes Plan. I want to ensure the ODNRA is 

following administration directives and has actively considered 

designation of federal and non-federal cooperating agencies in 

the preparation of analyses and documentation required by 

the National Environmental Policy Act (NEPA). I also want to 

ensure that Federal agencies actively participate as 

cooperating agencies in other agency's NEPA processes.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Langelier, Kelly I urge you to go back to the working group recommendations 

and not close ANY trail areas.

The report produced by the working group in 2009 did not

strictly advocate keeping all trails open. It was a collaborative

report that discussed several options that were rarely

unanimously supported by all members, but rather a range of

suggestions with varying levels of support. 

Langelier, Kelly Many of the trails slated for closure were at one time located 

in open dune areas but due to

previous mismanagement of the dunes the non-native 

vegetation has encroached into previously open areas leaving 

only the trails.

Areas of user-developed routes in MA 10 (C) occur in a

variety of vegetation in the ODNRA including plantations,

native vegetation and areas dominated by non-native

species. Please refer to Response #142 for a discussion on

existing vegetation in MA 10 (C) and its relationship to open

sand at the time the ODNRA was established.

Langelier, Kelly Your closure of the trails noted on the preferred alternative 4 

will

eliminate any management of the vegetation and will certainly 

result in loss of the dune habitat and replace it with 

forest/broom grass habitat.

Many areas of MA 10 (C) that are primarily vegetated by nonnative and invasive species are proposed to managed as

open to OHV use. Areas of native vegetation are, as directed

by the Dunes Plan, to be protected. Please refer to response

#4 for a discussion of the Forest's plans for dune restoration. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 314 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Langelier, Kelly There is NO!! mandate in the trail management plan that 

requires anybody to close any trails or open

areas- The DEIS only requires that the trail system be 

inventoried.

Managment of the ODNRA is guided by the 1994 Dunes Plan.

The Dunes Plan specifies that MA 10 (C) be managed to

"protect vegetated habitats while providing controlled

opportunties for offroad vehicle touring and traveling on

designated routes." The Dunes Plan also called for the

identification of additional designated routes within 3 years of

Plan approval. Not all of those routes were identified. This

project will identify those routes to be designated.

Langelier, Kelly There were many promises made to us during the 1994 

Recreation Area Management plan that were NEVER 

implemented ( Horsfall road sand road for beach access, 

Additional campgrounds

at Horsfall, Open access to the Coast guard road south of the 

Horsfall Beach parking area, Additional camping areas at 

Driftwood and many others) and these should be addressed 

before ANY changes

are made to the trail plan.

A list of recreation activities and projects can be found in the

Dunes Management Plan (page B-30). The Plan further

states that projects planned "Will be reviewed annually and

may be revised if management direction, priorities or on-theground conditions change. Revisions to the schedule will not

necessarily result in amendments to the Dunes Plan" (page B1). Furthermore, please note that several of the items listed in

this comment do not appear on the Resource Schedule.

Larson, Aaron If I had it my way, of coarse I would not only want what we 

currently have to remain open, but I would want you to open 

up more riding opportunities in previously closed off areas. I 

understand that may not happen, so I simple am asking to 

not take more away from what little we have left.

Changes to Management Areas other than MA 10 (C) of the

ODNRA, including those closed to motorized use, is outside

the scope of this project. The primary purpose and need for

the Project is to complete the designation and development of

a comprehensive, understandable designated OHV route

system that can be effectively managed and maintained within

the MA 10 (C) areas of the ODNRA. 

Larson, Aaron Another area I frequent is Cleawox Lake in Florence. There is 

a trail that leads right to the edge of the lake.

The 1994 Dunes Plan directs that designated routes within MA

10 (C) connect open riding areas or connect open riding areas

to the beach. This trail does not fit the parameters for

designated routes within MA 10 (C) as directed by the Dunes

Plan. An area near Cleawox Lake is proposed for reallocation

to open riding in Alternative 5.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 315 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Larson, Aaron Winchester has a trail from the Third finger down to the 

fourth finger.

 

Continued use by OHVs on trails that cross the fingers is not

sustainable ecologically. In addition, these trails cannot

provide sustainable, long term, challenging recreational

opportunities sought after by the public. Historic use at

Banshee Hill confirms this. The initial route across Banshee

Hill was narrow and challenging requiring skills and equipment

only a few people possessed. As use continued and

equipment became more powerful, the trail widened, down

cut, undercut native vegetation, and became less steep with

the sand being pushed downhill. Ecologically, this has

undercut and killed additional native vegetation and provided

opportunities for new non-native vegetation growth. The

recreation experience is no longer as challenging and riders

have begun to develop new, more challenging trails adjacent

to Banshee Hill. Closing Banshee Hill is not practical. 

Designating trail opportunities on other fingers and

forthcoming associated challenging user created trails does

not simplify OHV management. This cyclic pattern of

continuously seeking challenging trails is not sustainable long

term. 

Larson, Aaron Another is the trail to the left of Banshee hill. Banshee Hill is proposed to be reallocated to open riding in

Alternatives 2, 4 Modified 4 and 5.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 316 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Larson, Aaron The routes you have left open are some of the worst roads I 

have ever been on. These routes have heavy use and become 

whooped out and are very uncomfortable to drive down.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 317 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Larson, Aaron Many of the “user created routes” are actually there because 

the vegetation has grown up choking off the open sand and 

these routes are what’s left of the open sand.

Alternatives 2, 4 . Modified 4 and 5 propose reallocations to

open riding for some areas where user-developed routes exist

within non-native vegetation. Please refer to Response #136

for a discussion of open sand, changing vegetation conditions

and MA 10 (C) areas.

 The Forest has compiled 1979 aerial photos of the three

riding areas. We had incomplete photo coverage for 1972

photos. Those photos were then overlayed with the

boundaries of MA 10 (C) to determine the amount of formerly

open sand that is now included in MA 10 (C). This overlay

revealed that the amount the areas of open sand in 1979

coordinate closely with the areas of open riding in MA 10 (B),

and that the areas that appeared vegetated in 1979 are the

areas that are now MA 10 (C). Review of those photos, does

however show that there has been expansion of the deflation

plain westward, as suspected and that although the areas of

vegetation appear very similar, the density of the vegetation

has increased. It is important to acknowledge that this does

not mean areas of open sand have not been diminished by the

advancement of non-native vegetation; what appeared to be

open sand in 1979, now appears to have more areas of

European beachgrass and Scotch broom. 

Larson, Diana I am sending my letter of support for the Designated Routes 

Project.

Thank you for your comment.

Larson, Diana I feel you are doing what needs to be done and do not feel it 

will at all impact any economical aspects of our beautiful 

coastal region.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 318 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 319 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Laskey, Don They also infuse huge amounts of money into the local 

economies, economies hard hit by the same loss of timber 

revenues, not to mention the Great Recession.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 320 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Laskey, Don There is an unintentional fringe benefit to their continued use 

of the dunes: they are controlling the encroachment of 

European beachgrass and other resulting vegetation, on the 

Oregon dunes.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Lawrence, Mandy Attached please find the Department of the Interior's 

comments on the subject DEIS.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 321 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Layton, Christine We need the trails for our family to spend time together and 

in return, we help preserve the area by treading down noxious 

weeds that are not indigenous to the area.

Alternatives 2, 4, Modified 4 and 5 propose reallocations to

provide trail riding opportunities.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Layton, Christine option 5 is the best feasible choice Thank you for your comment.

Leif, Gary We have organized a group that is interested in the 10C 

Designated Routes Project and want to meet with Jerry.

This meeting occured on January 10, 2014.

Leif, Gary Frank Davis,

Thanks for you response. I've left messages with Julie 

Schriver, Jerrys Assistant and she has not returned my calls?

Thank you for your comment.

Leif, Gary 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 322 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mistrust comes from the fact that in 72', Congress established 

29K acres to the Dunes as a National Recreation Area

and then in the FS 79' plan, designated that 47% would be 

open to OHV and then again in 94' reduced it again to

46% to OHV to "various degrees". Yet here we are today with 

the new FS 10C plan and it designates 7K acres to open use 

by closing 10C, which is 25%, not the 47% indicated in 79'. I 

hope you can see the concern of the people, in the 

motivations of this new 10C Plan by the FS and how we 

"Mistrust" it, just from the past. Historically, if we give 

anything now, we will loose it forever, so enough is enough..

[...]The ODNRA Act directs the "administration, protection, 

and DEVELOPMENT of the recreation area". Unfortunately, the 

development language has been ignored in favor of the 

administration and protection language. OHV use is valid 

recreation. As I mentioned in my first topic, there is a 

"mistrust" of the Forest Service motivation and the Forest 

Service needs to put their best foot forward and actually 

provide 47% to the OHV, as indicated in the 79' Plan and not 

take away anymore areas, as suggested in this 10c DEIS Plan

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 323 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 324 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 325 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 326 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 327 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary In 1972 there was to be an "Advisory Committee" established 

to consult with the management of the Dunes

Recreation Areas. This has been ignored for 25 years, which 

has caused a lack of input on the 79 and 94

Management Plans and much of our suspicions would have 

been averted, had such a committee been advising.

You can see the mistrust from our nation in our leadership 

down to the States, Counties and Cities that perform daily 

activities. The people of this nation are unsure of who and 

what to believe, which causes further doubt when plans come 

out like this. The Riley Ranch is a good example of the 

suspicions of groups that want OHV use to simply go away. 

We are proud that the Forest Service endorsed the Riley 

Ranch Routes and happy that we were successful for OHV 

continued use, but not without litigation..[...]I recommend 

that an Advisory Committee be created before any decisions 

on any plan revisions, now or future and that this Advisory 

Committee will be at the local level and County level and will 

make recommendations that will

be followed out by the Forest Service.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 328 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary Non Native Vegetation was planted that has taken over the 

areas that were once open dunes. In your DEIS, you 

recognized this was happening, but you have done nothing to 

identify solutions to that. In the Deflation Plan, you show that 

as open, 108 rideable areas, but in fact, it is not. As you can 

see in this photograph, this area is un- rideable and offers no 

significant advantages for riders, with no solutions in your 10c 

plan to address this..

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 329 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary The coastline is a part of the original intent of the 1972 Dunes 

Recreation Area. The beach should have complete and 

unlimited access to this and your plan identifies 14 trails to be 

closed to the beach. I have been told that this was a flaw in 

your mapping, but still needs to be addressed. In addition, 

you show closures to the trails at Umpqua

#3, which surround a water table. 8ut that area is the only 

access we have to the beach for many months of the

year, while water prohibits the other trails access to the 

beach. Why close this area without access to the beach?

Neither the Act that established the ODNRA, nor the 1994

Dunes Plan which guides its management direct or advocate

complete and unlimited access to the beach.

H.R. 8763, which established the Oregon Dunes National

Recreation Area "to provide for the public outdoor recreation

use and enjoyment of certain ocean shorelines and dunes,

forested areas, fresh water lakes and recreational facilities..."

The 1979 Dunes Plan and the 1994 Dune Plan provided open

riding opportunities, but established restrictions for motorized

use in vegetated areas. Those vegetated areas within

motorized areas are allocated as Management Area 10 (C) in

the 1994 Dunes Plan. 

The 1994 Dunes Plan was prepared according to Secretary of

Agriculture regulations (36 CFR 219) which are based on the

Forest and Rangeland Renewable Resources Planning Act

(RPA) as amended by the National Forest Management Act of

1976 (NFMA). This plan was also developed in accordance

with regulations (40 CFR 1500) for implementing the National

Environmental Policy Act of 1969 (NEPA). The Dunes Plan

guides resource management activities and establishes

standards and guidelines for the Oregon Dunes NRA.

This Plan describes the goal of MA 10 (C) "to protect existing

vegetated areas while providing controlled opportunities for

OHV riding and travel on designated routes through the area

to reach the beach and other areas which are open to OHV

use." (Dunes Plan, III-36).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 330 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary Another example of flaws in your DEIS, is the fact that you 

imply that at the bottom of the fingers, or bottom of the 

horns, identify closed trails there. From first look you can't see 

yellow trails, but if you enlarge it, they are there.

Thank you for pointing out these mapping errors. We have

corrected the errors in the mapping of alternatives that

showed user-developed routes, in yellow, in areas that are MA

10 (B) that are open riding around the vegetated fingers in the

Middle Riding area. These are not user-developed trails

because they are within the area designated as open riding.

Leif, Gary Another great example of moving sand, which indicates a flaw 

in DEIS, where I call the 250 Hole, identified on the map.

The term "user-created" trails defines trails that have not been

designated, numbered or mapped by the Forest Service. It is

true that many of these trails existed prior to the 1979 or the

1994 Dunes Plans. However, both Plans envisioned a

designated route system through vegetated areas. This vision

was not fulfilled. With the 2005 Travel Management Rule,

forests were directed to designate roads, trails and areas that

are open to motorized travel. This was a change from forests

being open to motorized travel unless designated

closed. Management Area 10C was designated closed except

for designated routes in the 1994 Dunes Plan, however this

was not fully implemented. It was recognized during the

development of the Siuslaw Travel Management

Environmental Assessment that due to the fact that trails were

not designated, many areas on the ODNRA were not legally

accessible. This FEIS attempts to bring the ODNRA into

compliance with the 2005 Travel Management Rule by

designating trails and open areas within Management Area

10C and to make the designations comprehensive and

understandable that can be effectively managed and

maintained.

Leif, Gary That is pretty significant and we feel if you take more areas 

away, dunes enthusiasts will simply quit riding, causing more 

economic hardships in a failing economy. I see nothing in 

closing the 10c Routes that will help anything greater for the 

environment as opposed to ruining the economy of our 

communities..

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 331 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 332 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

were run today.

Leif, Gary In the open areas, people can come at any direction, 360 

degrees, providing more issues with unsafe areas. In fact, we 

rarely ride in the open areas, because of the safety issues. 8y 

removing the "trails" it almost certainly will prove fatal for 

many riders who would be forced to ride in the open.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Leif, Gary Perhaps the single most important part of my letter is here. 

This is the "Family" side of what you are proposing to do, the 

"Human Interest" side of things, which I don't feel is 

addressed adequately in your 10C plan.

Alternatives 2, 4, Modified 4 and 5 propose reallocations to

provide trail riding opportunities.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 333 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary As the Sheriff from Douglas County said, "How do you intend 

to enforce such a law that closes down good trails that people 

have been riding on for years and turn into them into 

criminals" and then he said "or not" which indicates they will 

not enforce what you propose anyway, because it simply a 

bad plan..

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 334 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 335 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary I feel it is your fiduciary duty to uphold the act as Congress 

original intended and your resources would be better spent on 

physical improvements to the areas instead of defending the 

failures and actions through costly litigation!

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Leif, Gary Public involvement in one of your criteria for DEIS, but yet in 

my conversations with hundreds of people, most are unaware 

of the gravity or scope or even what is proposed. Then 

beyond that, the timing of public input at the single lowest 

use of the dunes during wintertime, causes suspicion. I 

recommend that making very large, billboard type signs when 

actions like this are proposed at the main staging areas with 

links to the FS, STDR and any other effected organizations 

who would like to be involved. This is how to get the public 

notified, not just handing out flyers at certain times or posting 

a flyer on a reader board that is rarely read.[...]4. Create 

more public/private involvement with Dunes' management.

[...]6. Communicate and coordinate with all three different 

Counties. Make sure they are represented and informed and 

have a majority say in the process.

The Forest followed laws, policies and regulations in soliciting

input for this project. The Siuslaw National Forest began

seeking information from the public in regard to the

Designated Routes project in 2009, when the Forest hired an

independent contractor to assemble and facilitate a working

group of individuals with varied interests in the Oregon Dunes.

In 2010, this working group provided ideas regarding a system

of designated trails and open riding areas that they believed

would meet the 1994 Dunes Plan. The results of their work

was posted to the Forest website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 336 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 130 comments on the DEIS.

Leif, Gary Recognize that your plan has many flaws and rather than 

continue this plan, simply move these recommendations to 

the 2014 plan revision that is already required to come in the 

future and work on that plan.

At one time the Siuslaw national Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 337 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary 1. Change all the 10C areas to 108, which follows intent of the 

original law and eliminates the need for management of trails 

because they are self maintained and clearly shows that the 

trials I've identified is simply the natural dynamic progression 

of the dunes, not "user created" as you inaccurately define.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Leif, Gary 2. Re-open Spinreel to Winchester Dunes for OHV use, as was 

intended in ODNRA.

It is outside the scope of this analysis to rezone any areas not

within Management Area 10 (C).

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Oregon Dunes National

Recreation Area currently has about 34 miles of designated

trails and about 5,930 acres of designated areas for open

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 338 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

motorized travel. As the Siuslaw National Forest developed its

2009 Travel Management Plan, it became apparent that since

not all the MA 10 (C) routes had been designated, some areas

within the motorized portions of the ODNRA were largely

inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10C to motorized cross-country travel and

allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Three alternatives (2, 4, and 5) analyze rezoning Management

Area 10C (designated routes only) to Management 10B (open)

in varying degrees. 

Leif, Gary 3. Re-open Dunes, north of Winchester 8ay. 

Opening additional areas to motorized vehicles is outside the

scope of this project. On November 9, 2005, the Travel

Management Rule was published in the Federal register. Prior

to the Travel Management Rule, National Forests were open

to motorized travel unless designated closed. Now, under the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 339 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Travel Management Rule, National Forests are closed to

motorized travel unless designated open. The Oregon Dunes

National Recreation Area currently has about 34 miles of

designated trails and about 5,930 acres of designated areas

for open motorized travel. As the Siuslaw National Forest

developed its 2009 Travel Management Plan, it became

apparent that since not all the MA 10 (C) routes had been

designated, some areas within the motorized portions of the

ODNRA were largely inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10 (C) to motorized cross-country travel

and allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Four alternatives (2, 4, Modified 4 and 5) analyze reallocating

Management Area 10 C (designated routes only) to

Management 10 (B) (open) in varying degrees. It is outside

the scope of this analysis to consider changes in motorized

access within in any areas not designated as Management 10

(C).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 340 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leif, Gary Start the restoration process that needs to happen, before you 

start to close.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Leif, Gary If you choose to close areas, I support a 2 for one swap. If 

you close 1 acre, give us 2 acres back of useable, challenging 

areas..

 

Opening additional areas to motorized vehicles is outside the

scope of this project. On November 9, 2005, the Travel

Management Rule was published in the Federal register. Prior

to the Travel Management Rule, National Forests were open

to motorized travel unless designated closed. Now, under the

Travel Management Rule, National Forests are closed to

motorized travel unless designated open. The Oregon Dunes

National Recreation Area currently has about 34 miles of

designated trails and about 5,930 acres of designated areas

for open motorized travel. As the Siuslaw National Forest

developed its 2009 Travel Management Plan, it became

apparent that since not all the MA 10 (C) routes had been

designated, some areas within the motorized portions of the

ODNRA were largely inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 341 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Management Area 10 (C) to motorized cross-country travel

and allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Four alternatives (2, 4, Modified 4 and 5) analyze reallocating

Management Area 10 C (designated routes only) to

Management 10 (B) (open) in varying degrees. It is outside

the scope of this analysis to consider changes in motorized

access within in any areas not designated as Management 10

(C).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 342 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leiken, Sid Lane County feels very strongly the congressionally mandated 

Advisory Committee

must be reconstituted. We have previously noted that the 

Forest Service appears to be

out of compliance with the Oregon Dunes National Recreation 

Act of 1972 (PL 92-260,

Section 12(a)). Within our own organization we regularly and 

formally create and

recognize advisory committees to guide our, and our 

Department's, actions. It is our

expectation that the Forest Service follow what is clearly 

provided for in law with respect

to this Advisory Committee.[...]Related to comment 1 is that 

Federal law is quite clear with respect to consulting with

Lane County in its role as a cooperating agency. In fact, while 

we are pleased that the

comment period for this plan was extended, we were not 

formally alerted to this

opportunity by the USFS, and only learned of it through the 

communications of our

concerned citizenry.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 343 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Leiken, Sid We question the finding that non-designated routes within the 

MA 10 (C) areas have

created " .. . greater and unnecessary impacts to important 

plant communities .. ".; This

finding appears to conflict with other statements indicating 

the prevalence of non-native,

invasive vegetation such as European beachgrass and Scotch 

broom within MA 10 (C).

We would urge a finding that continues to recognize the full 

4,455 acres within that area

be designated Open Riding 10 (B).

The impacts of OHVs to vegetation, wildlife, fisheries and

hydrology are documented in the DEIS, FEIS and in the

specialist reports. 

Leiken, Sid The economic analysis provided as part of the USFS Draft 

Environmental Impact

Statement analysis is severely flawed. The finding of no 

economic impact must not

remain in the final EIS, and we would ask that your office 

examine the analysis provided

by Oregon State University on the economic benefit to Lane, 

Douglas, and Coos

Counties provided by OHV users and visitors (many of whom 

travel here from Canada).

This analysis shows $86M of economic impact. The USFS 

finding of $2.5M per year is

without merit.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 344 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

LIZEWSKI, ED YES to requiring mufflers on ORVs

that meet sanctioned motocross event requirements.

Muffler requirements are outside the scope of this project. 

LIZEWSKI, ED Yes to closing illegal ORV routes. Thank you for your comment.

LIZEWSKI, ED NO to opening new areas to ORVs. Thank you for your comment.

Lodwig, Ethan The SNF should open more acres to OHV recreation in the 

ODNRA[...]Please add another alternative to the DEIS that 

makes sense, that opens more acres to open riding.

Please refer to response #123 for a discussion of the range of

alternatives developed to meet the purpose and need for this

project. Alternatives 2, 4, Modified 4 and 5 would

reallocate additional acres from MA 10 (C) to open riding as

MA 10 (B).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 345 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Lodwig, Ethan The open sand that has been enjoyed by people for 

thousands of years is disappearing and OHV recreation is your 

only viable choice at stopping the destruction of the sand 

dunes

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Lowe, Travis I am deeply saddened by the forest services idea that closing 

the Dunes will help anyone or anything. That whole area was 

set aside for the public to use in many ways including OHV 

activity.

The Siuslaw National Forest is not proposing to close the

Dunes. This primary purpose and need for the Project is to

complete the designation and development of a

comprehensive, understandable designated OHV route

system in Management Area 10 (C). This Management Area

encompasses 4,455 acres of the 28,900 acres that make up

the Oregon Dunes National Recreation Area (ODNRA). This

project would not affect any other Managment Areas, except

to possibly increase the acres in Mangement Area 10 (B),

wherin open riding is permitted. Non-motorized areas of the

ODNRA where recreational activities such as hiking occur

are not affected by this project.

Madlock, Jennifer All the designated roads at Sprinreel and the Hauser area are 

very important acess points to get to the beach.

No alternatives propose any changes to existing designated

routes.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 346 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mates, Susan Please do not expand areas for off-road vehicle use Two areas are managed primarily for OHV use at the Oregon

Dunes. Those areas are called Management Area 10 (C)

wherein OHVs are permitted on designated routes only and

Management Area 10 (B), open riding. This project addresses

only Management Area 10 (C). Changes are proposed to MA

10 (C), but no changes are proposed to expand areas

for OHVs into areas that are not currently managed for OHV

use to some degree. The rationale for reallocating areas of

MA 10 (C) to MA 10 (B) includes the predominance of nonnative vegetation. Please refer to Chapter 2 of the DEIS and

FEIS for more information on the rationale for proposals for

reallocations to open riding.

Mates, Susan I am willing to "share" this habitat through a responsible 

system of designated routes through vegetated areas, but I 

cannot support revisions that would expand these open riding 

areas.

The intent of this project is not to protect non-native vegetation

and invasive species. The rationale for proposing reallocations

from MA 10 (C) to open riding in MA 10 (B) reflect this intent

and the Forest believes that proposed reallocations will fulfill

the purpose and need of project including the development of

an enforceable and understandable system of designated

routes and areas. For further discussion for the rationale for

proposals, please refer to pages 56-58 and FEIS.

Mates, Susan OHVs should be limited to open sand, but some open sand 

must also remain non-motorized.

Restricting or reducing the number of acres managed for OHV

use at the ODNRA is outside the scope of this project. The

purpose and need of this project is to designate routes within

MA 10 (C). Approximately 46% of the ODNRA is managed for

OHVs to some degree. Of that 46%, about 21% is managed

for open riding in areas of open sand and 4,455 acres or 15%

are managed for OHVs on designated routes only. This

project addresses only those 4,455 acres. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 347 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mates, Susan please protect and save native vegetation and wetlands, and 

honor your promises for

the ecological restoration of the Oregon Dunes that was called 

for in the original 1994 Dunes Plan.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Mates, Susan In addition, I hope that you will actively enforce the Forest 

Service policies for OHV usage, as well as making sure that 

users are well aware of these policies.[...]I am offended by 

the idea that off-road vehicle users could be "compensated" 

for a presumed loss of a usage area that has been illegal and 

unauthorized

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 348 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 349 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

May, Damon With the current economic issues facing the nation as a whole 

I feel this action of continued OHV closure would only serve to 

further diminish the economic basis in the coastal area.[...]

The closure to OHV would also diminish revenue to the 

National Forest by reduction of OHV permits.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 350 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

McCall, Donald As a fulltime resident living on Cleawox Lake, I have a strong 

vested interest

in the outcome of the proposals. I plan to live the rest of my 

life on the lake, and I am

very frequently out on the lake in my kayak (or canoe or 

rowboat) or hiking near and

along its shores. The noise that can be heard from the OHV s 

creates a very negative

impact on what is otherwise an extremely serene and 

beautiful experience. There is a

point midway down the west side ofthe lake where people 

often ride their OHVs all the

way to the shore of the lake. I used to think that it was nice 

that the riders could share the

beauty of the area, but all too many of those who go there 

seem to enjoy revving their

engines to excess. I also frequently clean up trash from this 

area. The noise is clearly

heard from my home as well as when I am on the lake.

Therefore, I feel it is best to keep a reasonable noise barrier 

area away from the Cleawox

The impacts of noise on non-motorized recreation and nearby

communities was incorporated into the design of all

alternatives, please refer to discussion of "Issues" in Chapter

1. Modified Alternative 4, the Preferred Alternative, does not

propose designated routes or reallocation to open riding to the

areas west of Cleawox Lake in order to address the user

conflicts that occur resulting from the impact of OHV noise on

non-motorized recreation and local communities.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 351 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

McCall, Donald I strongly support the selection of Alternative TWO

• If this option is not viable, then my second choice would be 

to support Alternative

FOUR

Thank you for your comment.

McCall, Donald The LEAST acceptable alternative would be number five, as it 

opens up areas that lie

entirely too close to Cleawox Lake and the residential areas.

Thank you for your comment.

mcfadden, peter OHV recreation has already been "minimized" enough by 

previous NEPA decisions[...]In 1972, approximately 28,000 

acres were open for legal OHV use. After implementation of 

the 1979 ODRNA Management Plan, the acreage available for 

OHV use was reduced, by about 47%, down to 15,000 acres. 

When the 1994 ODNRA Management Plan was adopted, the 

acreage available for open riding was reduced significantly to 

5,930 acres.[...]Between 1972 and 2011, the acreage 

available for open OHV use has been reduced from 28,000 

acres down to just below 6,000 acres. Just 20 percent of the 

NRA is available for legal OHV use today.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 352 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 353 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 354 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 355 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 356 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

mcfadden, peter Vegetation and dune management should dovetail with 

recreation management as part of a coordinated strategy.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

mcfadden, peter The purpose and need should have been broadened to 

address the legislative intent of the original National 

Recreation Area Act.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 357 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

mcfadden, peter The project should address active and effective vegetation 

management alternatives, which can complement, and 

potentially be enhanced by, effective recreation management.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

mcfadden, peter active sand dunes should be a desired condition and 

encroachment of non-native vegetation is a "significant issue" 

that must be addressed.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

mcfadden, virgil Please withdraw the current DEIS and associated public 

comment period, conduct supplemental analysis and issue a 

supplemental EIS to include and seek input on additional 

alternatives to those presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 358 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 359 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

mcfadden, virgil anyone who has purchased a ohv permit should be informed 

by letter from the oregon dunes national recreation area 10 c 

of the fatal changes that could occur without notice.

The Forest followed laws, policies and regulations when

informing the public of this project and soliciting input. 

mckiddy, paul Not everyone enjoys straight open dune riding, but the 

challenges a trail provides to enhance your skill level and 

enjoyment.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 360 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Means, Dan About 1/5 of the terrest has off-road stuff. And if you keep 

messing up the sanddowns to off-road stuff the terrest whith 

off-road stuff won't stop in Florence. This is bad for Florence 

and it's bussness that depends on terrest to stay open!

Thank you for your comment.

Mello, Jeff We need more space, more opportunity, and more dunes to 

play on NOT less.

Changes to Management Areas other than MA 10 (C) of the

ODNRA, including those closed to motorized use, is outside

the scope of this project. The primary purpose and need for

the Project is to complete the designation and development of

a comprehensive, understandable designated OHV route

system that can be effectively managed and maintained within

the MA 10 (C) areas of the ODNRA. 

meyer, jane Perhaps closing down the hill on South Jetty area where the 

decibel levels of OHV's climbing the steep hill are way beyond 

legal levels would be a good idea.

Changes to Management Area 10 (B) are outside of the scope

of this project. The area known as South Jetty Hill is in

Management Area 10 (B), Off-Road Vehicle Open. The

purpose of this project is to designate routes and areas within

Management Area 10 (C). 

Sound limit enforcement continues to be a management

priority as well as a challenge. Enforcement activities include

voluntary sound checks, rider education and citations for

violations. Your concern has been noted and we welcome

input to assist us in improving sound compliance among

riders. 

meyer, jane In general I support most of the measures proposed in 

Alternative 4 of the Draft EIS. However, strict enforcement of 

decibel levels via regular monitoring and elimination of the 

rider created trails is a must.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 361 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Midddling, Ann The purpose and need should have been broadened to 

address the legislative intent of the original National 

Recreation Area Act

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Midddling, Ann The project should address active and effective vegetation 

management alternatives, which can complement, and 

potentially be enhanced by, effective recreation management. 

In short, the Oregon Dunes present a unique situation where 

active sand dunes should be a desired condition and 

encroachment of non-native vegetation is a "significant issue" 

that must be addressed.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Miller, Joshua do not shut down or minimize our riding area(s[...]The trails 

are the best part of our riding experience.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 362 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 363 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 364 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 365 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 366 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Miller, Joshua Closing our trails/dunes not only effects the valuable family 

time I am able to spend w/my family and even extended 

family it will also have an effect on your local economies.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 367 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Miller, Kathleen Please do not back down to the sustained push to open more 

trails to OHV riders.

Thank you for your comment.

Miller, Kathleen Maybe one would like to listen to the ocean in peace in some 

places. They would ride the coast till there wasn’t one living 

thing left.

Motorized vehicle use on beaches is managed by the Oregon

Department of Parks and Recreation. Not all beaches

adjacent to the ODNRA are open to motorized vehicles. The

beach south of the Siltcoos Beach parking lot is closed to

motorized vehicles. The beach west of the Umpqua riding

area is also closed to motorized use.

Miller, Logan Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 368 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

I believe that by closing areas u have listed will not only hurt 

the families and businesses of your communities it will also 

hurt many many families that look forward to the wonders 

and great atomoshpere the dunes offer.I urge you to please 

reconsider for the community, families, and all of the 

businesses that not only rely on the people from the dunes for 

income reasons but for the atmosphere and family stronghold 

it really is.

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 369 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Minten, Linda You haven't listed a deadline date of anything you sent me... 

Just that I have 45 days. How will anyone know when the 

start date was so they will be able to get it in in time? Is this 

another deceptive tactic or am I just missing it? Please let me 

know - thanks, Lindy

Minten, Linda When the committee was formed we noticed the lack of OHV 

participants involved and felt it odd that others would have an 

equal or greater say to OHV matters. Simply put, why would a 

mushroom grower (a commercial grower) have as much or 

more say on a recreational issue? Consider also their use is 

part-time, limited in area, and rarely disturbed by the OHVers. 

They use our trails to access their picking areas. This is just 

one example but there are more....

Please refer to FEIS, Chapter 2 Alternatives. Several

alternatives were analyzed in the FEIS, from No Action to

varying degrees of designated routes and rezoning

Management Area 10 (C) - Designated Routes only to

Management Area 10 (B) - Open. Alternatives 1, 2 and 3 do

not rezone any of the Shore Pine areas to Open

Riding. Alternatives 4 and Modified 4 rezone some of the area

to Open Riding (A10 - 33 acres) and Alternative 5 rezones

more (A12 -50 acres and A13 - 112 acres).

Minten, Linda We have the FS dictating a plan when the FS has failed for 

years to manage the area. We have the FS looking at 

environmental impact statements regarding “damage” done 

by the OHVers when clearly the biggest threat to the dunes is 

the many invasive non-native species the FS intentionally 

planted years ago and has neglected to control. By the FS 

actions and inactions they have become the biggest risk to the 

ODNRA and yet we still allow them to remain in control of the 

area? Ironically OHV activity is one of the best tools we have 

available to save the dunes. Even environmental groups 

support OHV activity in this area. We are not the problem – 

mismanagement by the FS is.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 370 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Minten, Linda I would like to see an environmental impact done on the 

damages to the ODNRA over the past hundred years as a 

result of the FS actions, and inaction.

This is outside the scope of this project. However, the

description of the affected environment and existing

conditions discuss how past actions have resulted in the

current condition, from non-native planting to foredune

creation and user-created trails.

Minten, Linda If the goal is to save the Dunes then two things need to 

happen. The first is to remove these lands from the FS care. 

Clearly the FS has not been able to adequately manage them. 

Additionally, they are not a viable commercial forest and have 

been designated recreation. There is a direct conflict. Return 

these public lands to the State for management. Secondly, 

manage the area to remove and manage the invasive species 

that were intentionally planted to include restoration to the 

dunes original state before the government agencies came up 

with their brilliant plan.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 371 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Minten, Linda Specifically I firmly believe the FS has intentionally misled the 

public using deceptive practices. One example is with 

terminology. The OHV public, as well as the public in general, 

defines trails as what you refer to as “user created trails”. 

Then you define authorized trails as what we would consider 

roads. It is referring to a “freeway” as a single dirt road. Very 

misleading and I believe very intentional.

The term "user-created" trails defines trails that have not been

designated, numbered or mapped by the Forest Service. It is

true that many of these trails existed prior to the 1979 or the

1994 Dunes Plans. However, both Plans envisioned a

designated route system through vegetated areas. This vision

was not fulfilled. With the 2005 Travel Management Rule,

forests were directed to designate roads, trails and areas that

are open to motorized travel. This was a change from forests

being open to motorized travel unless designated

closed. Management Area 10C was designated closed except

for designated routes in the 1994 Dunes Plan, however this

was not fully implemented. It was recognized during the

development of the Siuslaw Travel Management

Environmental Assessment that due to the fact that trails were

not designated, many areas on the ODNRA were not legally

accessible. This FEIS attempts to bring the ODNRA into

compliance with the 2005 Travel Management Rule by

designating trails and open areas within Management Area

10C and to make the designations comprehensive and

understandable that can be effectively managed and

maintained.

Minten, Linda Many of these trails have also been maintained – possibly by 

the FS themselves and are considered to meet Trail Class 2 

standards (Page 140 “Little input was needed because all 

designated routes proposed are existing user-developed 

routes needing little, if any improvement to meet Trail Class 2 

Standards”). Trees fall and yet the downed trees are cut up 

and removed from the trail. So for years millions of visitors to 

these areas have been riding these trails without event. New 

trails that are started are quickly posted closed. The message 

was – these are open, these are closed.

Trails not designated will be obliterated or allowed to revert

naturally. In response to comments asking for more

information, we have included more specifics in the Project

Design Criteria of the FEIS. Closures are also addressed in

the Wildlife Biological Assessment.

Minten, Linda In 2010-2011, the Off Highway Vehicle Crew resigned

all existing designated routes in accordance with Travel

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 372 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

BUT – now the FS refers to these trails as illegal user created 

trails and identifies only the roadways (that you deceptively 

call trails) as the only legal avenue for travel. Then you post a 

sign, about a year ago, on one of these roadways that 

instructs riders to stay on the trails. Very deceptive and the 

timing is suspect. Basically what it appears you have done is 

to mislead the public once again. They are staying on the 

trails but what you haven’t said, or enforced, or defined well 

for the public is that you meant roads, I mean trails, or you 

know, user created trails are illegal but you can stay on the 

trails that really are roads..

Management regulations and sign/poster guidelines (EM-7100

-15 Chapter 6, 6a, 6b). This amounted to removing signs

which had been in place since approximately 1995 and

upgrading them with signage in line with new standards. The

goal was not only to comply with Travel Management

regulations, but also to offer something more consistent and

useful across the entire motorized NRA. 

 

Routes which did not exist in INFRA were not signed. Only

the core network of routes as currently seen on the ODNRA

OHV Guide/Map brochure were signed. 

 

In areas where existing designated routes pass through

MA 10 (C) or wetlands areas of MA 10 (G), white/black

regulatory “Cross-Country Travel Prohibited – Stay on

Routes Shown on Use Map.” Once the rider exits that

portion they will see “Cross Country Travel Allowed –

Stay in Area Shown on Use Map.” Through areas where

cross-country travel is prohibited, the designated route

is the only legal avenue for travel and is signed as such. 

 

 

Brown directional signs name the route, the route’s trail

number as shown in the MVUM, and any helpful

information such as mileage to next intersection, beach,

or facility. These were a major step forward from the

previous directional signs which merely named the route

and were often incorrectly located along routes and

inconsistently placed at intersections. 

 

In many of these existing routes, brown “carsonite”

markers or 12x18 “OHV Closure” signs have been

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 373 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

standing for many years marking the same areas offroute as closed, as these new Travel Management signs

now do.

Minten, Linda By your definition you are not closing trails – only user 

created trails. To the public it simply means you are closing all 

of the trails and they can only legally travel on the roads that 

you call trails. (page 68 “Currently, the public are not 

reasonably aware that travel through MA 10C is permitted on 

designated routes only.”) Since 1994?

After publication of the Motorized Vehicle Use Map (MVUM) in

2009, any trails within MA 10 (C) that were not designated

routes, were closed. The purpose of this project is to

complete the designation and development of a

comprehensive, understandable designated OHV route

system within MA 10 (C) areas of the ODNRA. 

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on existing unmaintained trails within

vegetated areas. Please refer to the Recreation section in

Chapter 3 for further information on the acknowledged value

of trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 374 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Minten, Linda That brings us to Alternative 1 – this clearly shows the 

deception to the public. It says no action will be taken. It will 

remain as it is. Many in the public will be ecstatic with this 

option BUT it is because no change for them means they can 

legally continue to ride on all the trails they have been riding 

on for years but just can’t create new ones. For the FS it 

means they go back to the 1994 plan that was never 

implemented or signed and all “trails” will be closed.

The no-action alternative provides a baseline for estimating

the effects of other alternatives. A no action alternative is

required in an EIS (40 CFR 1502.14(c)). The no-action

alternative portrays the implementation of the 2009 Siuslaw

Travel Management Project Decision. The implementation of

this Decision would be the closure of motorized vehicle

use within Management Area 10C except for the designated

routes that were identified in the Plan and displayed in the

Motor Vehicle Use Map. The 2009 Siuslaw Travel

Management Plan recognized the lack of designated routes

and deferred implementation of the Plan within Management

Area 10C until the completion of the Designated Routes

Project. The existing condition is described, but it does not

meet the purpose and need. The FEIS, Chapter 3,

Environmental Consequences describes the existing condition

in the affected environment for the resources, but only

describes direct, indirect and cumulative effects for the

alternatives considered, including the No Action Alternative.

Minten, Linda That brings me to my second point. 10-B was open for riding 

meaning you could ride cross-country, create as many dang 

trails around the plantation pine and clumps of invasive grass 

as desired. Now that it has grown in with invasive specie’s we 

have to protect it and there is an accusation that the trails 

were made illegally by the riders

Managment Areas were designated in the 1994 Dunes

Plan. The boundaries of MA 10 (B) and MA 10 (C) remain

unchanged. In alternatives 2, 4, Modified 4 and 5, this project

proposes to reallocate areas that were designated as MA 1O

(C) in the 1994 Plan, thereby increasing the number of

areas areas that are considered open riding as MA 10 (B).

Vegetatated areas such as pine plantations existing when the

ODNRA was established in 1972, as evident on historical

aerial photos, and have not been managed as open riding

areas. Vegetated areas, including what are now designated

as MA 10 (C), have been managed to permit OHV on

designated routes only. 

Minten, Linda The entire area was open to riding – the mismanagement by 

the FS to not contain the invasive species is the issue

 Without question, invasive species are a huge issue at the

Oregon Dunes NRA. The Forest has been conducting

restoration work for several years. In 2013, Forest began

work on a larger scale Dune Restoration strategy in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 375 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

partnership with concerned citizens. 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 376 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

Minten, Linda Those trails that you close – do you expect them to revert to 

sand or grow over with more invasive species? It is the free 

flowing sand that needs protected. So clearly Alternative 1 

would be the worst option for the OHVers and the 

environment.

Please refer to the Project Design Criteria in Chapter 2 for

further information for trail closures.

Minten, Linda Converting 10B to 10C – That opens up a huge can of worms 

for the FS. To protect the dunes the reverse would be most 

beneficial

The rationale for reallocating areas of MA 10 (C) to MA 10 (B)

are discussed in Chapter 1 and in table 26 of

the FEIS. Areas of MA 10 (C) not designated as routes are

closed to motorized use.

Minten, Linda This is in part by starting with Alt. 1 suggesting to the public 

there will be no change when in fact it is a total trail closure.

The no-action alternative provides a baseline for estimating

the effects of other alternatives. A no action alternative is

required in an EIS (40 CFR 1502.14(c)). The no-action

alternative portrays the implementation of the 2009 Siuslaw

Travel Management Project Decision. The implementation of

this Decision would be the closure of motorized vehicle

use within Management Area 10C except for the designated

routes that were identified in the Plan and displayed in the

Motor Vehicle Use Map. The 2009 Siuslaw Travel

Management Plan recognized the lack of designated routes

and deferred implementation of the Plan within Management

Area 10C until the completion of the Designated Routes

Project. The existing condition is described, but it does not

meet the purpose and need. The FEIS, Chapter 3,

Environmental Consequences describes the existing condition

in the affected environment for the resources, but only

describes direct, indirect and cumulative effects for the

alternatives considered, including the No Action Alternative.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 377 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Minten, Linda This document and its supporting evidence was not made in a 

way that the public can understand or reasonably comment. 

Most will be discouraged and confused. Was this intentional 

misleading or an unintentional act simply due to your depth 

and understanding of the topic? Either way, it is your 

responsibility to insure it is easy enough for the public to 

understand so they can make an informed comment. I do not 

believe you have succeeded.

The Forest followed laws, policies and regulations in making

this document available to the public and addressing

questions and concerns. In 2009, an independent working

group comprised of people with varied interests in the Dunes

was formed to develop ideas for how to designate routes and

areas in Management Area 10 (C). Throughout the more than

one year that the group met, meetings were held that were

open to the public. Forest Service officials attended and were

available to answer questions from the public. When the

Forest officially began the planning process, a Notice of Intent

to prepare an EIS was published in the Federal Register on

June 24, 2011. A scoping letter was mailed to approximately

150 individuals, groups and agencies. Over 800 scoping

comment letters were received, as well as petitions containing

nearly 6,500 signatures and comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The Draft EIS was placed in public libraries and was

available at the Forest Service offices in Reedsport, Waldport

and Corvallis. 

The Forest hosted an open house in Reedsport on November

17, 2012. At the request of the public the comment period

was extended an additional 45 days. Another open house

was held in Eugene in January, 2013. Other meetings with

interested members of the public took place in Corvallis in

December, 2012 and in Roseburg in January, 2013. In

addition the Forest met with the Coos, Douglas, and Lane

County Commissioners. In an ongoing effort, Forest Service

personnel have been available to meet with interested parties

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 378 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

both individually and in groups and to answer questions

regarding this project for over three years. 

Minten, Linda Clearly most in the OHV world will opt for Alternative 5. It 

appears to give the OHV community something when it is 

really simply still taking a massive amount away. It is the only 

option that allows access to the lake.

Thank you for your comment.

Minten, Linda Obviously when only given these choices I too would pick 

Alternative 5. It is like picking between bad or worse and I 

feel that this whole process has been flawed and misleading 

from the start. Clearly the outcome is what I had expected 

based on the Land issues in other areas. The FS saved the 

most heavily used for last so they wouldn’t bring attention to 

the less used and easier to close areas.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 379 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Minten, Linda Without legal intervention the public will be left out of the 

process then restricted from PUBLIC lands.

The Forest followed laws, policies and regulations in soliciting

input for this project. The Siuslaw National Forest began

seeking information from the public in regard to the

Designated Routes project in 2009, when the Forest hired an

independent contractor to assemble and facilitate a working

group of individuals with varied interests in the Oregon Dunes.

In 2010, this working group provided ideas regarding a system

of designated trails and open riding areas that they believed

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 380 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

would meet the 1994 Dunes Plan. The results of their work

was posted to the Forest website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 130 comments on the DEIS.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 381 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Minten, Linda I suggest the FS should focus on returning the ODNRA to its 

pre 1930’s condition.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Minten, Linda The data was not listed and likely not studied but I feel it is 

imperative to any decision made. What is the NEPA data for 

leaving things with the current use to include all user created 

trails. There should have been an option for this as well rather 

than or in addition to the Alt. 1 where no action would be 

taken.[...]If no action would be taken then you need to take 

into consideration the continued use without change. This 

process is incomplete without that information.

Please refer to the DEIS and FEIS, Chapter 2, for a discussion

of the exisiting condition and the distinction between the

current condition and the No Action altrnative. 

Minten, Lindy One of my biggest concerns,and one that I have personally 

shared with you, is insuring all of the options consider and 

address safety issues. Especially with regard to children. I 

have reviewed the plan and was very disappointed with the 

lack of significance given to child safety issues. Children are 

not able to traverse many of the areas shown that will be 

designated. Many of the trail systems they use will no longer 

be allowed. As you are aware, the ODNRA is at significant risk 

to a Tsunami leaving little time for those riding to evacuate to 

higher ground. Children, with less access to options, as well 

as adults, will be at a greater risk for loss of life.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 382 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Minten, Lindy When I sat in a Ways and Means Committee meeting for 

funding by NOAH for sea floor mapping they made it clear 

there would be less than eight minutes for evacuation after an 

earthquake. They also made it clear the risk was great. Why 

isn’t there information with regard to this risk in the report? 

Was it even considered initially? Will it be now?

Earthquake evacuation plans are outside the scope of this

project.

Minten, Lindy Additionally, less riding area for more people simply means an 

increased risk for all. Certainly this issue needs to be 

addressed and given a reasonable study.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Mogstad, Joni There is a mandate (40 C.F.R. and 1501.6 and 1508.5) that 

Federal agencies responsible for preparing NEPA analysis and 

documentation do so “in cooperation with State and local 

governments” and other agencies with jurisdiction by law or 

special expertise. (42U.S.C. 4331(a), 4332(2)). Failure to 

formally consult with the counties precludes the agency from 

meeting its statutory mandate. These C.F.R. and U.S.C. 

directives are in addition to the specific directions in the Act 

(see sections 12 and 14) that require cooperation with the 

State and with counties.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Mogstad, Joni 

In 1972, Public Law 92-260 established the Oregon Dunes

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 383 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The foundation for this current process is a nearly 20 year old 

Management Plan that established “Zone management” and 

set up the 10 - C zones or areas that attempt to lead one to 

believe that the 10 - C acres (estimated at 4,455 acres) are 

open to OHV travel.[...]The reality is that there are about 10 

miles of trail on the 4,000 plus acres.

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 384 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

6. In the future, permits may be required to limit number of

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 385 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

users to -acceptable levels.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 386 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 387 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 388 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mogstad, Joni To the casual rider, the existence of the 10 -C zones have 

been transparent or non existent, yet the Forest Service 

insists that enforcement of this nearly 20 year old decision 

that has not been previously enforced is the No Action 

alternative.[...]There is in fact no No Action alternative and by 

basing this current process on an outdated foundation, the 

alternatives or options have been limited.

The no-action alternative provides a baseline for estimating

the effects of other alternatives. A no action alternative is

required in an EIS (40 CFR 1502.14(c)). The no-action

alternative portrays the implementation of the 2009 Siuslaw

Travel Management Project Decision. The implementation of

this Decision would be the closure of motorized vehicle

use within Management Area 10C except for the designated

routes that were identified in the Plan and displayed in the

Motor Vehicle Use Map. The 2009 Siuslaw Travel

Management Plan recognized the lack of designated routes

and deferred implementation of the Plan within Management

Area 10C until the completion of the Designated Routes

Project. The existing condition is described, but it does not

meet the purpose and need. The FEIS, Chapter 3,

Environmental Consequences describes the existing condition

in the affected environment for the resources, but only

describes direct, indirect and cumulative effects for the

alternatives considered, including the No Action Alternative.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 389 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mogstad, Joni Failure to address lack of Federal Advisory Committee:

Section 12 of the original Act directs the Secretary of 

Agriculture to establish and Advisory Council to consult with 

on a periodic and regular basis with respect to management 

and development of the recreation area. This is an 

independent statutory obligation essentially ignored by the 

agency for the last 25 years. At one point there was a 

memorandum indicating the agency was going to ignore the 

“Advisory Council” direction because it was expensive to 

constitute and maintain an Advisory Council. The lack of input 

from this council could explain the significant loss of 

motorized access to the NRA in the development of both of 

the previous management plans.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 390 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mogstad, Joni There is no alternative presented that considers the part OHV 

use might play in controlling the invasive beach grass and no 

recognition that the trails through Pine plantations emerged 

because the pine plantations were planted to control the 

movement of the dunes. If the Dunes were still alive and 

open, there would be no (or few) trails or routes to 

“designate”. I would like to see an alternative presented that 

considers the possibility of enlisting OHV users to assist with 

returning the dunes to a more natural state.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Mogstad, Joni stop this process and conduct a supplemental Environmental 

Impact Statement that considers, evaluates and incorporates 

the above.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 391 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 392 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Mogstad, Joni This forest is scheduled for a Forest Plan Revision in 2014. I 

can see this “plan” serving to influence the Forest Plan 

Revision in ways not favorable to OHV users. The EIS does 

not analyze or even discuss this project’s impacts on the upcoming Forest Plan Revision. I believe there are elements of 

the EIS alternatives that may serve to significantly impact the 

Forest Plan Revision. A Supplemental EIS will allow you to 

discuss this possibility and to assure us this project will not set 

a “closure oriented” tone during future planning efforts.

At one time the Siuslaw national Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Monett, David I oppose a plan that will put all terrain vehicles in smaller 

areas. That is dangerous!

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Monett, David the trees and plants mentioned in the News Review 22 

January hardly meet threatened status.

The 1994 Dunes Plan, which guides management of the

Oregon Dunes NRA, directs that MA 10 (C) be managed to

protect existing vegetated areas.(Dunes Plan, III-36). It does

not direct that only threatened or endangeried species be

protected.

Monett, David Economic impact first!! Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 393 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 394 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Monett, David Areas need to be expanded. The primary purpose and need for the Project is to complete

the designation and development of a comprehensive,

understandable designated OHV route system that can be

effectively managed and maintained within the MA 10 (C)

areas of the ODNRA. Alternatives 2, 3, 4 Modified and 5

would expand the miles of designated routes in the ODNRA.

Alternatives 2, 4 and 5 would reallocate acres to open riding

as MA 10 (B) , thus expanding OHV trail riding opportunities.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 395 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

morgan, kelly OHVs should be limited to open sand, The 1994 Dunes Plan describes management areas wherein

OHV use is permitted. Areas of the ODNRA open to cross

country OHV travel are in Management Area 10 (B), which is

primarily open sand. The Dunes Plan also directs that OHVs

will be permitted in some vegetated areas, but restricted to

designated routes in the vegetated areas known as MA 10

(C). The primary purpose of this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA, as directed by the 1994 Plan. 

Additionally, some vegetated areas wherein OHVs are

restricted to designated routes are dominated by non-native

vegetation. The intent of this project is not to protect nonnative vegetation. Therefore, four alternatives to the proposed

action suggest reallocating areas of MA 10 (C) to open riding. 

Additionally, some areas currently allocated as MA 10 (C) are

proposed for reallocation to open riding. The rationale for

those reallocations can be found in Chapter 2 of the DEIS and

FEIS.

Conversely, the Dunes Plan also identified areas of open sand

that wherein OHVs would not be permitted. Examples include

the areas west of the Oregon Dunes Day Use Area, and the

Tenmile Creek Research Natural Area (RNA). No reduction in

acres within areas managed for non-motorized activities are

proposed in any of the alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 396 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

morgan, kelly some open sand must also remain non-motorized. The 1994 Dunes Plan describes management areas wherein

OHV use is permitted. Areas of the ODNRA open to cross

country OHV travel are in Management Area 10 (B), which is

primarily open sand. The Dunes Plan also directs that OHVs

will be permitted in some vegetated areas, but restricted to

designated routes in the vegetated areas known as MA 10

(C). The primary purpose of this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA, as directed by the 1994 Plan. 

Additionally, some vegetated areas wherein OHVs are

restricted to designated routes are dominated by non-native

vegetation. The intent of this project is not to protect nonnative vegetation. Therefore, four alternatives to the proposed

action suggest reallocating areas of MA 10 (C) to open riding. 

Additionally, some areas currently allocated as MA 10 (C) are

proposed for reallocation to open riding. The rationale for

those reallocations can be found in Chapter 2 of the DEIS and

FEIS.

Conversely, the Dunes Plan also identified areas of open sand

that wherein OHVs would not be permitted. Examples include

the areas west of the Oregon Dunes Day Use Area, and the

Tenmile Creek Research Natural Area (RNA). No reduction in

acres within areas managed for non-motorized activities are

proposed in any of the alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 397 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

morgan, kelly the Forest Service should follow through on promises made to 

begin ecological restoration of the Oregon Dunes, which was 

called for in the original 1994 Dunes Plan

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

morgan, kelly The Forest Service needs to make a commitment to inform 

OHV riders of designated routes with clear signage, wildlifefriendly fencing, and active enforcement.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 398 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 399 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

morgan, kelly Please drop the A16 open riding area in order to protect 

Tenmile Research Natural Area (RNA) and Snowy Plover 

Critical Habitat.

The boundary line separating the Umpqua riding area and the

Tenmile Research Natural Area (RNA) is posted as closed to

OHVs with signs on wooden posts. During field observations

over that last eight years, this line of staggered signing

through the open sand of MA 10 (B) has been an effective

deterrent to OHVs. The only user-created route entering the

RNA from the area south of A16 has been barricaded at the

Coos/Douglas County line and has been monitored for the

past four years.

morgan, kelly Choose Alternative Three (3) around Horsfall Lake. Thank you for your comment.

morgan, kelly Area A14 should be dropped to protect predominantly native 

vegetation.

A14 is not proposed in action alternatives 2, 3, 4 or Modified 4.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 400 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

morgan, kelly This kind of destructive recreation needs to be minimized, not 

expanded.

The 1994 Dunes Plan describes management areas wherein

OHV use is permitted. Areas of the ODNRA open to cross

country OHV travel are in Management Area 10 (B), which is

primarily open sand. The Dunes Plan also directs that OHVs

will be permitted in some vegetated areas, but restricted to

designated routes in the vegetated areas known as MA 10

(C). The primary purpose of this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA, as directed by the 1994 Plan. 

Additionally, some vegetated areas wherein OHVs are

restricted to designated routes are dominated by non-native

vegetation. The intent of this project is not to protect nonnative vegetation. Therefore, four alternatives to the proposed

action suggest reallocating areas of MA 10 (C) to open riding. 

Additionally, some areas currently allocated as MA 10 (C) are

proposed for reallocation to open riding. The rationale for

those reallocations can be found in Chapter 2 of the DEIS and

FEIS.

Conversely, the Dunes Plan also identified areas of open sand

that wherein OHVs would not be permitted. Examples include

the areas west of the Oregon Dunes Day Use Area, and the

Tenmile Creek Research Natural Area (RNA). No reduction in

acres within areas managed for non-motorized activities are

proposed in any of the alternatives.

morgan, kelly The erosion, exhaust, noise pollution, and damage caused to 

plant and animal life by off-road vehicles and other thrillcraft 

at the Oregon Dunes, and elsewhere, is well documented.

Please refer to the DEIS and FEIS for a discussion of the

affected environement and direct and indirect impacts of the

alternatives on recreation and user conflicts, botany, and

wildlife.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 401 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

morgan, kelly Native vegetation and wetlands must be protected and 

safeguarded from motorized recreation.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

morgan, kelly Maintenance and protection of the 10F designation at Beale 

Lake.

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Morris, John Alternative #1 comes closest to meeting the needs of ALL 

outdoor recreators.

Thank you for your comment.

Mueller, Family I feel that if we have this taken away that it will not be fair. Thank you for your comment.

Murphy, Heidi Area A14: Area A14 is unusable to OHV because it is heavily 

forested and under water a significant portion of the year.[...]

Whereas, the area directly to the right of Hunter’s Road 

designation on the FS maps is not underwater, contains 

invasive and non-native species (see example from this area 

in figure three below) and provides trail riding experience to 

OHV.[...]If this area were to be closed it will be backfilled with 

European beach grass and Scotch Broom as seen in this 

picture taken of this on 12/1/2012.

A14 is not proposed for reallocation in action alternatives 2, 3,

4 or Modified 4. The reallocations of A1 and A3, lying east of

Hunter's designated routes are proposed for reallocation to

open riding in Alternatives 2, 4, Modified 4 and 5. A3 has been

expanded from 6 acres to 27 acres in Alternataive 4-modified.

Murphy, Heidi 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 402 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Seasonal (Winter) designated route from Spinreel to 

Winchester Bay: 10J (Wild and Scenic River Designation, 

1,265 acres) Tahkenitch and Ten Mile are not designated as 

“Wild and Scenic” http://www.rivers.gov/rivers/oregon.php

[...]MITIGATION for proposed closures:

Opening additional areas to motorized vehicles is outside the

scope of this project. On November 9, 2005, the Travel

Management Rule was published in the Federal register. Prior

to the Travel Management Rule, National Forests were open

to motorized travel unless designated closed. Now, under the

Travel Management Rule, National Forests are closed to

motorized travel unless designated open. The Oregon Dunes

National Recreation Area currently has about 34 miles of

designated trails and about 5,930 acres of designated areas

for open motorized travel. As the Siuslaw National Forest

developed its 2009 Travel Management Plan, it became

apparent that since not all the MA 10 (C) routes had been

designated, some areas within the motorized portions of the

ODNRA were largely inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10 (C) to motorized cross-country travel

and allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Four alternatives (2, 4, Modified 4 and 5) analyze reallocating

Management Area 10 C (designated routes only) to

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 403 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Management 10 (B) (open) in varying degrees. It is outside

the scope of this analysis to consider changes in motorized

access within in any areas not designated as Management 10

(C).

Murphy, Heidi All trails classified as 10c shall be reviewed for non-native 

and/or invasive vegetation and reallocated to a 10 b 

designation as appropriate.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Murphy, Heidi Area A14: Area A14 is unusable to OHV because it is heavily 

forested and under water a significant portion of the year.

A14 was included in Alternative 5. It is not included in action

alternatives 2, 3 4 or Modified 4.

Murphy, Heidi Whereas, the area directly to the right of Hunter’s Road 

designation on the FS maps is not underwater, contains 

invasive and non-native species (see example from this area 

in figure three below) and provides trail riding experience to 

OHV. Per page 79 of the DEIS, “Where the surrounding 

vegetation adjacent to the trail is primarily non-native and 

invasive, it could be expected that in the long-term, without 

active restoration, these same species would dominate the 

former trail through plant dispersal through wind, animals, 

and natural population increase.” If this area were to be 

closed it will be backfilled with European beach grass and 

Scotch Broom as seen in this picture taken of this on 

12/1/2012.

The Hunter's designated route runs through nearly the entire

North Riding Area. Many ares to the east of this route are wet

and densely vegetated and upon site inspection, show little

use from motorized vehicles. The area to the east of the route

and to the north of the proposed reallocation of A3 is

generally dryer and more sparsely vegetated. In response to

comments that this area should be considered for reallocation,

the proect interdisciplinary team visited the site. The area has

been added as a proposed reallocation in Alternative 4-

Modified. This addition would increase the A3 reallocation

from 5.8 acres to 27.3 acres.

Murphy, Heidi MITIGATION for proposed closures: Seasonal (Winter) 

designated route from Spinreel to Winchester Bay: 10J

 

Opening additional areas to motorized vehicles is outside the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 404 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

scope of this project. On November 9, 2005, the Travel

Management Rule was published in the Federal register. Prior

to the Travel Management Rule, National Forests were open

to motorized travel unless designated closed. Now, under the

Travel Management Rule, National Forests are closed to

motorized travel unless designated open. The Oregon Dunes

National Recreation Area currently has about 34 miles of

designated trails and about 5,930 acres of designated areas

for open motorized travel. As the Siuslaw National Forest

developed its 2009 Travel Management Plan, it became

apparent that since not all the MA 10 (C) routes had been

designated, some areas within the motorized portions of the

ODNRA were largely inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10 (C) to motorized cross-country travel

and allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Four alternatives (2, 4, Modified 4 and 5) analyze reallocating

Management Area 10 C (designated routes only) to

Management 10 (B) (open) in varying degrees. It is outside

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 405 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the scope of this analysis to consider changes in motorized

access within in any areas not designated as Management 10

(C).

Murphy, Heidi (Wild and Scenic River Designation, 1,265 acres) Tahkenitch 

and Ten Mile are not designated as “Wild and Scenic” 

http://www.rivers.gov/rivers/oregon.php

Management Area 10 (J), as described in the 1994 Dunes

Plan, are "Proposed Wild and Scenic Rivers" (Dunes Plan, p.

III-48). The Dunes Plan states the goal for this Management

Area as maintaining the river's free-flowing characteristics; to

protect and, if practicial enhance the outstandly remarkable

values of the river and its immediate environment (Dunes

Plan, Chapter III, page 48). 

Murphy, Heidi All other trails: All trails classified as 10c shall be reviewed for 

non-native and/or invasive vegetation and reallocated to a 10 

b designation as appropriate.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Murphy, Heidi I advocate for a plan which calls for the restoration of the 

dunes, to include areas that are currently designated as 10 C 

to be reviewed for non-native and/or invasive vegetation.[...]

The dunes need to be restored NOW, not on an “only a near 

foreseeable project” (page 130 DEIS) basis.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 406 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi Those areas found to contain non-native or invasive 

vegetation shall be reallocated as 10 B.[...]I request you 

remedy this by first reviewing all areas of 10c for invasive and 

non-native vegetation. Any of these areas that contain 

invasive and/or non-native vegetation should be moved to a 

10 b designation. This would be a “modified version of the 

alternative 5” presented within the DEIS, 10/2012.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Murphy, Heidi No question that Open Sand is Dying: 80% of the Open Sand 

within the ODNRA is Gone and the Forest Service is not 

Focused on Restoration!

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Murphy, Heidi In the Forest Service document, “Off Highway Vehicle (OHV) 

Designated Routes Working Group Oregon Dunes National 

Recreation Area” dated October, 2010, Siuslaw National 

Forest, the Forest Service states, “It appears that there are 

areas where eliminating non-native vegetation such as 

European beach grass and restoring historically open sand 

areas would be a reasonable management objective” (page 

71).

The working group report is not a Forest Service document. In

2009, an independent working group comprised of people

with varied interests in the Dunes was formed to develop

ideas for how to designate routes and areas in Management

Area 10 (C). An independent facilitator assembled the group,

led meetings and submitted a final report on behalf of this

independent group. Throughout the more than one year that

the group met, meetings were held that were open to the

public. Forest Service officials attended and were available to

answer questions from the public. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 407 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi Dunes Restoration Cannot Be Removed From Scope of the 

DEIS 10/2012

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Murphy, Heidi Alternative 1 (page iii of the DEIS) states, “No Action; no 

additional routes designated and enforcing all user-developed 

routes as closed.”

A no –action alternative is required by CEQ (40 CFR 1502.14

(d). This alternative forms the basis of comparison between 

meeting the project needs and not meeting the project needs. 

This alternative provides baseline information for 

understanding changes associated with the action 

alternatives.

However, we are not presented with a no-action alternative in 

the DEIS dated 10/2012.[...]A no-action alternative would 

entail no closures (no action from present conditions).

The no-action alternative provides a baseline for estimating

the effects of other alternatives. A no action alternative is

required in an EIS (40 CFR 1502.14(c)). The no-action

alternative portrays the implementation of the 2009 Siuslaw

Travel Management Project Decision. The implementation of

this Decision would be the closure of motorized vehicle

use within Management Area 10C except for the designated

routes that were identified in the Plan and displayed in the

Motor Vehicle Use Map. The 2009 Siuslaw Travel

Management Plan recognized the lack of designated routes

and deferred implementation of the Plan within Management

Area 10C until the completion of the Designated Routes

Project. The existing condition is described, but it does not

meet the purpose and need. The FEIS, Chapter 3,

Environmental Consequences describes the existing condition

in the affected environment for the resources, but only

describes direct, indirect and cumulative effects for the

alternatives considered, including the No Action Alternative.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 408 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi The DEIS provides no baseline information for understanding 

the changes associated with the action alternatives.

The no-action alternative provides a baseline for estimating

the effects of other alternatives. A no action alternative is

required in an EIS (40 CFR 1502.14(c)). The no-action

alternative portrays the implementation of the 2009 Siuslaw

Travel Management Project Decision. The implementation of

this Decision would be the closure of motorized vehicle

use within Management Area 10C except for the designated

routes that were identified in the Plan and displayed in the

Motor Vehicle Use Map. The 2009 Siuslaw Travel

Management Plan recognized the lack of designated routes

and deferred implementation of the Plan within Management

Area 10C until the completion of the Designated Routes

Project. The existing condition is described, but it does not

meet the purpose and need. The FEIS, Chapter 3,

Environmental Consequences describes the existing condition

in the affected environment for the resources, but only

describes direct, indirect and cumulative effects for the

alternatives considered, including the No Action Alternative.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 409 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi This DEIS does not consider a full range of alternatives. The 

range of alternatives are not broad enough and a wider range 

of alternatives for OHV use must be considered.

No specific number of alternatives is required (42 USC 4332,

102(c)(iii) and E, 36 CFR 220.b(2)), but rather alternatives are

driven by cause-and-effect-statements. The range of

reasonable alternatives includes both alternatives that warrant

detailed analysis and alternatives that are considered, but

eliminated from detailed study. The Forest Service developed

five alternatives, including the No Action alternative, in

response to the issues raised by the public, by other agencies

and internally. Two additional alternatives were considered

but eliminated from detailed study. Alternatives provide

different ways to fulfill the purpose and need and address

unresolved conflicts related to the proposed action. All

alternatives are discussed in chapter 2 of DEIS and FEIS,

including issues that drove the development of alternatives

and a table comparing alternatives. 

In response to comments on the DEIS, an additional

alternative, Modified 4 was developed. Including the No

Action Alternative, five alternatives to the proposed action

were developed. 

Murphy, Heidi Economics and safety are removed from scope per page 12 of 

the DEIS document dated 10/2012. The DEIS states that “of 

the eight issues, six were believed to be directly related to the 

decision to be made and measurable among the various 

alternatives, such that differences between the alternatives for 

that issue could be readily and clearly displayed.” The two 

issues that were removed from scope include economics and 

safety.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 410 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Murphy, Heidi Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 411 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The DEIS clearly does not discuss effects of safety nor 

economics, while NEPA mandates that they do. “The agency 

has the responsibility to make an informed judgment, and to 

estimate future impacts on that basis, especially if trends are 

ascertainable or potential purchasers have made themselves 

known. The agency cannot ignore these uncertain, but 

probable, effects of its decisions.”

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 412 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

were run today.

Murphy, Heidi I will delve further into the economic analysis in a subsequent 

comment. The study conducted by the Forest Service has 

severe limitations and potential for error.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 413 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Murphy, Heidi Safety:

On page 14 of the DEIS, it states, “Currently, there is no 

accurate, reliable way of tracking injuries to OHV riders within 

the riding areas at the ODNRA.” In fact, the Oregon Health 

Authority (OHA), Injury Prevention and Epidemiology Program 

does just that. In my professional capacity as a Research 

Analyst with the OHA Injury Prevention and Epidemiology 

Program, I presented at the Oregon ATV Law Enforcement 

Conference held in Redmond, OR during April of 2012 on ATV 

safety data for the Oregon Dunes. I plan to present again this 

year in April. I am currently preparing an ATV Injury and 

Death Report for the time period of 2005 – 2011 for Oregon 

that will be available within the next month. The ODNRA is 

within the sentinel area (Coos Bay, Winchester Bay, Florence, 

and Sand Lake) and data does, in fact, exist. Instances of 

both injuries and deaths are submitted to the OHA by local 

law enforcement within each jurisdiction among other data 

collection methods, including the Oregon Trauma Registry. So, 

in fact, there is a baseline to consider the alternatives against. 

The DEIS further states that “Past history at the Dunes seems 

to indicate that even in popular, most congested areas of the 

ODNRA vehicle on vehicle accidents are rare and most rider 

injuries occur in lower density areas, due to people operating 

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 414 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

machines beyond their skill/competency level, and not from 

crashing into one another.” This is obviously not based on 

data, since it was stated that “no data exist.” The DEIS further 

states on page 14 that “Rider density can be a partial 

detriment to rider safety...” According to the Oregon Dunes 

National Recreation Area Visitor Survey, Robert Burns, March 

2008, the majority of 2006 visitors felt that the number of 

people they saw (crowding acceptability) was unacceptable, 

75% of those surveyed. Further, according to the “Oregon 

Mandatory All-Terrain Vehicle Safety Education Program 

Development, Determine Best Practices in ATV Safety 

Education”, March 1, 2008, page 9, “In dunes areas, the 

safety problem is exacerbated when large numbers of ATVs 

operate in restricted areas such as Oregon’s Sand Lake 

Recreation Area and California’s Oceano Dunes and Imperial 

Dunes Recreation Areas. Safety and law enforcement issues 

seemed quite consistent between the Oregon Dunes and 

other similar recreation areas.” With preferred alternative 

four, 84 miles of riding area would be closed. Concentrating 

riders into a smaller area within this acreage only adds to the 

problem of crowding and safety is a paramount concern.

Murphy, Heidi NEPA does not mandate closure. On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. Designating routes and areas

as open or closed to motorized vehicles is directed by the

Travel Management Rule.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 415 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi The Forest Service does not use their own data when 

referring to the “Trail riding experience.” On page iii of the 

DEIS it is stated that “Open sand, largely unrestricted riding, 

had been and remains the primary draw for OHV 

recreationists to the Oregon Dunes ODNRA.”

Trail riding is only marginally lower than open dune riding 

(open dunes riding preferred by 36.4 % of respondents, trail 

riding, 31.8%). This is data directly from the Forest Service, 

“Oregon Dunes National Recreation Area Visitor Survey”, 

Robert Burns, March, 2008, page 43. Again, the Forest Service 

clearly knows about this data. It is referenced in the “Off 

Highway Vehicle (OHV) Designated Routes Working Group 

Oregon Dunes National Recreation Area” dated October, 2010, 

Siuslaw National Forest, yet not cited in the DEIS.

The Dunes Plan directs that MA 10 (C) be managed to permit

OHVs on designated routes only. Through the scoping

process, many people commented on the value of the trail

riding experience that could not be accomodated on

designated routes. In response to these comments from the

public, the Forest developed alternatives with reallocations of

areas from MA 10 (C) to MA 10 (B) open riding areas to

provide the desired trail riding experience.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 416 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi If the Forest Service were simply following the Travel 

Management Rule, placement of signs would have occurred 

by 2010 (as required by 36 CRF 212, Subpart B, Designation 

of Roads, Trails, and Areas for Motor Vehicle Use) and not 

during July, 2011 as they were. Here are the pictures of these 

signs in place:

Resigning all existing designated routes in accordance with

Travel Management regulations and sign/poster guidelines

(EM-7100-15 Chapter 6, 6a, 6b) occurred after signs were

ordered and delivered, and then when staff was available to

install them. Activities included removing an equal number of

signs which had been in place since approximately 1995 and

upgrading them with signage in line with new standards. The

goal was not only to get into compliance with Travel

Management regulations, but also to offer something more

consistent and useful across the entire motorized ODNRA. 

 

Routes which did NOT exist in INFRA were not signed. Only

the core network of routes as currently seen on the ODNRA

OHV Guide/Map brochure were signed. 

 

In areas where existing designated routes pass through MA

10 (C ) or wetlands areas, white/black regulatory “CrossCountry Travel Prohibited – Stay on Routes Shown on Use

Map” were installed. Once the rider exits that portion they will

see “Cross Country Travel Allowed – Stay in Area Shown on

Use Map.” Brown directional signs name the route, the route’s

trail number as shown in the MVUM, and any helpful

information such as mileage to next intersection, beach, or

facility. These were a major step forward from the previous

directional signs which merely named the route and were

often incorrectly located along routes and inconsistently

placed at intersections. 

 

In many of these existing routes, brown “carsonite” markers or

12x18 “OHV Closure” signs have been standing for many

years marking the same areas off-route as closed, as these

new Travel Management signs now do. 

 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 417 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi •Some areas around Shore Pines are proposed for closure due 

to mushroom picking. However, according to the “Record of 

Decision: Dunes Management Plan, Oregon Dunes NRA 

Siuslaw National Forest, (page 13), mushrooms are a 

commercial activity. The document states, “...I view them 

(timber and mushrooms) as secondary to the primary stated 

objectives of the NRA; specifically, those objectives relating to 

recreation opportunities and conservation of resources 

discussed in the NRA act.”

Please refer to FEIS, Chapter 2 Alternatives. Several

alternatives were analyzed in the FEIS, from No Action to

varying degrees of designated routes and rezoning

Management Area 10 (C) - Designated Routes only to

Management Area 10 (B) - Open. Alternatives 1, 2 and 3 do

not rezone any of the Shore Pine areas to Open

Riding. Alternatives 4 and Modified 4 rezone some of the area

to Open Riding (A10 - 33 acres) and Alternative 5 rezones

more (A12 -50 acres and A13 - 112 acres).

Murphy, Heidi Among all the alternatives within the DEIS, the spread of 

invasive plants due to OHVs is considered.

Please refer to FEIS, Chapter 3, Botanical Resources where it

states, "Non-native invasive plants are spread by wind, water,

animals, and people. one mechanism of plant spread is

vehicles that pick up sees and plant parts on their tires, body,

and chassis, transporting them to other locations where they

drop off and potentially start new infections. No specific

information was found that looks at the role OHV's may have

in the spread of invasive plants in the ODNRA. Else where, it

has been shown that vehicles do spread invasive plants, and

that potential to transport seed increases when the vehicle

travels off-road, and that the amount of seed that is carried by

the vehicle increases in wet conditions (MSU 2011). Because

sandy soils do not stick to vehicles in the same way as finer

loam or clay, the results of these studies may not be directly

appliciable to conditions in the project area, but some seed

transport by vehicles cannot be ruled out as well as the

potential to introduce seed from other areas outside of the

ODNRA where the vehicle may have been. The potential to

introduce or spread invasive plants by vehicle and what

degree of impact that has on other resources can be ranked.

Designating areas of largely native vegetation to open OHV

use would have the greatest risk of impact, followed by new

construction of designated routes through native vegetation

within Management Area 10 (C), designating an existing userResponse to Comment (By Comment Author)

Response to Comment (By Comment Author) 418 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

developed trail within native vegetation, and least impacting,

designating a user-developed trail through non-native

vegetation or opening an area of non-native vegetation to

open OHV use." It also states, "Intensive OHV use can reduce

or eliminate the colonization of invasive European beachgrass

and an argument could be made that reallocating areas from

Management Area 10 (C) to 10 (B) may provide some control

of this species. To be effective however, high frequency and

duration of use would need to be maintained over an entire

area. Because areas proposed for reallocation were selected

for their potential to provide trail riding opportunities, use

patterns would not likely result in any real reduction in

European beachgrass."

Murphy, Heidi On page 130 of the 10/2012 DEIS it states, “A foreseeable 

project in the near future is a dune restoration plan. Due to 

the fact that this plan has yet to be developed and is only a 

near foreseeable project, the exact cumulative effects cannot 

be calculated.” Yet on page 51 of the DEIS 10/2012, we are 

told “The Forest has initiated a more comprehensive approach 

to restoration with interested members of the public.” Which 

is it?

A Dune Restoration plan has been initiated, but has not been

completed. For further discussion of Dune Restoration please

refer to Response #3.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 419 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi Page 67 of the DEIS states “In 1994, the current Dunes Plan 

was adopted, zoning 46% of the ODNRA as open to OHV use 

to various degrees. This number includes MA 10 (b ), where 

open riding is permitted, as well a Management Areas 10 (c ), 

10 (g ), and 10 (l ), where OHV is permitted on designated 

routes only.” Management Area 10 (g ) is Wetlands Emphasis. 

On Nov. 29th I requested the alternative maps showing the 

10 (g) and L designations from Angie Morris. I received a 

response from Angie on Nov. 30th that Management Area (g) 

is out of scope. Management area L does exist on the North 

Riding Area Map, although shows no “designated trails” within 

this management area. If Management Areas G and L are 

calculated in the 46% of area open to OHV use, these, in fact, 

are not out of scope and need to be included on each of the 

alternative maps. Since these areas are open to OHV use to 

various degrees, this should be calculated on the amount of 

acres actually open to OHVs. OHVs are not allowed to ride in 

the entire area designated as “ORV on Designated Routes”, 

nor on “Developed Corridors.” It is also highly suspect that 

OHVs ride anywhere within the “Noise Control Buffer” area 

since no designated routes appear on any of the alternative 

maps. We were denied maps with “wetlands emphasis” so, 

again, it is suspect that OHVs are allowed to ride within this 

area at all and no conclusion can be drawn. I request that 

areas open to OHV be calculated properly and all Alternative 

maps be redesigned to include Management Area 10 G.

The DEIS does not describe 46% of the ODNRA as open to

cross country OHV travel.

The DEIS and the FEIS state, "In 1994, the current Dunes

Plan was adopted, zoning 46% of the ODNRA as open to

OHV use to various degrees. This number includes MA 10(B),

where open riding is permitted, as well as Management Areas

10(C), 10(G), and 10(L), where OHV use is permitted on

designated routes only." (FEIS, Chapter 3, Recreation,

Cumulative Effects. The 11 management areas and their

primary emphasis and associated acres were provided in the

DEIS, Chapter 1, Background, p. 8 and can be found in the

FEIS Chapter 1, Background. Management area acreage

percentages that are included in the 46% that allow OHV use

to varying degrees are as follows; MA 10(B) Off-Road Vehicle

Open (21%), MA 10(C) ORV on Designated Routes (15%), 

MA 10(G) Wetlands Emphasis (9%) and MA 10(L) Noise

Control Buffer (1%).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 420 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi I also request that an Advisory Council specific to the ODNRA 

be established, to oversee and provide valuable input into the 

work of the Forest Service. This is a requirement of the 1972 

Dunes Plan, which states,[...]SEC. 12. (n) The Secretary shall 

establish an advisory council for the Oregon Dunes National 

Recreation Area and shall consult on a periodic and regular 

basis with respect to matters relating to management and 

development of the recreation area. The members of the 

advisory council, who shall not exceed fifteen in number, shall 

serve for individual staggered terms of three years...”

The Advisory Council was terminated on June 6th, 1977, by 

the signature of John R. McGuire, Chief, as “part of the 

government-wide effort to reduce reliance upon Advisory 

Committees.” We are currently in the age of Advisory 

Councils, which bring great guidance, input, and knowledge to 

the programs and agencies they serve. Within the State of 

Oregon Injury Program, we have an Advisory Council for the 

Prescription Drug Monitoring Program, State Trauma Registry, 

and Injury Prevention, just to name a few. Within State 

government overall, they proliferate programs and serve them 

with much needed guidance. As evidenced, the Forest Service 

needs this guidance and oversight.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Murphy, Heidi Area A14: Area A14 is unusable to OHV because it is heavily 

forested and under water a significant portion of the year

A14 was included in Alternative 5. It is not included in action

alternatives 2, 3 4 or Modified 4.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 421 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi Whereas, the area directly to the right of Hunter’s Road 

designation on the FS maps is not underwater, contains 

invasive and non-native species (see example from this area 

in figure three below) and provides trail riding experience to 

OHV. Per page 79 of the DEIS, “Where the surrounding 

vegetation adjacent to the trail is primarily non-native and 

invasive, it could be expected that in the long-term, without 

active restoration, these same species would dominate the 

former trail through plant dispersal through wind, animals, 

and natural population increase.”

The Hunter's designated route runs through nearly the entire

North Riding Area. Many ares to the east of this route are wet

and densely vegetated and upon site inspection, show little

use from motorized vehicles. The area to the east of the route

and to the north of the proposed reallocation of A3 is

generally dryer and more sparsely vegetated. In response to

comments that this area should be considered for reallocation,

the proect interdisciplinary team visited the site. The area has

been added as a proposed reallocation in Alternative 4-

Modified. This addition would increase the A3 reallocation

from 5.8 acres to 27.3 acres.

Murphy, Heidi MITIGATION for proposed closures: Seasonal (Winter) 

designated route from Spinreel to Winchester Bay:

 

Opening additional areas to motorized vehicles is outside the

scope of this project. On November 9, 2005, the Travel

Management Rule was published in the Federal register. Prior

to the Travel Management Rule, National Forests were open

to motorized travel unless designated closed. Now, under the

Travel Management Rule, National Forests are closed to

motorized travel unless designated open. The Oregon Dunes

National Recreation Area currently has about 34 miles of

designated trails and about 5,930 acres of designated areas

for open motorized travel. As the Siuslaw National Forest

developed its 2009 Travel Management Plan, it became

apparent that since not all the MA 10 (C) routes had been

designated, some areas within the motorized portions of the

ODNRA were largely inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10 (C) to motorized cross-country travel

and allow motorized travel on the designated routes. Second,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 422 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Four alternatives (2, 4, Modified 4 and 5) analyze reallocating

Management Area 10 C (designated routes only) to

Management 10 (B) (open) in varying degrees. It is outside

the scope of this analysis to consider changes in motorized

access within in any areas not designated as Management 10

(C).

Murphy, Heidi All other trails: All trails classified as 10c shall be reviewed for 

non-native and/or invasive vegetation and reallocated to a 10 

b designation as appropriate.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 423 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi 10J (Wild and Scenic River Designation, 1,265 acres) 

Tahkenitch and Ten Mile are not designated as “Wild and 

Scenic”

Management Area 10 (J), as described in the 1994 Dunes

Plan, are "Proposed Wild and Scenic Rivers" (Dunes Plan, p.

III-48). The Dunes Plan states the goal for this Management

Area as maintaining the river's free-flowing characteristics; to

protect and, if practicial enhance the outstandly remarkable

values of the river and its immediate environment (Dunes

Plan, Chapter III, page 48). 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 424 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Heidi On September 4th, 2009 an Economic study entitled, “The 

Economic Impacts of Off-Highway Vehicle (OHV) Recreation in 

Oregon, was released by Kreg Lindberg of OSU, prepared for 

the Oregon Parks and Recreation Department. The study 

showed that 81.4 million dollars were spent on OHV trip 

expenditures on the south coast of Oregon (p.15) and 

accounts for 829 jobs (p. 16). The Forest Service completed 

their own study in 2011 with starkly different results. Their 

study states that “The ODNRA contributes about 2.5 million 

annually to the three counties within which the ODNRA is 

located (Coos, Douglas, and Lane). It accounts for about 82 

jobs within the three county area (p.137). The Roseburg and 

Florence Chambers of Commerce have both echoed concerns 

in their letters to the Forest Service that these numbers being 

presented by the Forest Service are not representative of the 

current state within their respective counties.[...]The Forest 

Service survey contains inherent potential for errors and 

uncertainty that they do not acknowledge. They would benefit 

from more transparency about the methods they used and 

discussion about the potential for errors in the data that they 

used. The counties affected by this crucial decision (Coos, 

Douglas, and Lane) as well as the general public, need to be 

informed of all the data limitations for this study. Many items 

that I pointed out within this letter point to some substantially 

critical errors within the Forest Service study. Each study has 

limitations and the correct answer may lie somewhere in the 

middle of the spectrum, but certainly 2.5 million and 82 jobs 

SEVERELY undercounts the potential economic impact 

imposed by your decision.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests.

Murphy, Patrick Area A14: Area A14 is unusable to OHV because it is heavily 

forested and under water a significant portion of the year.

A14 was included in Alternative 5. It is not included in action

alternatives 2, 3 4 or Modified 4.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 425 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Patrick Whereas, the area directly to the right of Hunter’s Road 

designation on the FS maps is not underwater, contains 

invasive and non-native species (see example from this area 

in figure three below) and provides trail riding experience to 

OHV. Per page 79 of the DEIS, “Where the surrounding 

vegetation adjacent to the trail is primarily non-native and 

invasive, it could be expected that in the long-term, without 

active restoration, these same species would dominate the 

former trail through plant dispersal through wind, animals, 

and natural population increase.”

The Hunter's designated route runs through nearly the entire

North Riding Area. Many ares to the east of this route are wet

and densely vegetated and upon site inspection, show little

use from motorized vehicles. The area to the east of the route

and to the north of the proposed reallocation of A3 is

generally dryer and more sparsely vegetated. In response to

comments that this area should be considered for reallocation,

the proect interdisciplinary team visited the site. The area has

been added as a proposed reallocation in Alternative 4-

Modified. This addition would increase the A3 reallocation

from 5.8 acres to 27.3 acres.

Murphy, Patrick MITIGATION for proposed closures: Seasonal (Winter) 

designated route from Spinreel to Winchester Bay: 10J

 

Opening additional areas to motorized vehicles is outside the

scope of this project. On November 9, 2005, the Travel

Management Rule was published in the Federal register. Prior

to the Travel Management Rule, National Forests were open

to motorized travel unless designated closed. Now, under the

Travel Management Rule, National Forests are closed to

motorized travel unless designated open. The Oregon Dunes

National Recreation Area currently has about 34 miles of

designated trails and about 5,930 acres of designated areas

for open motorized travel. As the Siuslaw National Forest

developed its 2009 Travel Management Plan, it became

apparent that since not all the MA 10 (C) routes had been

designated, some areas within the motorized portions of the

ODNRA were largely inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10 (C) to motorized cross-country travel

and allow motorized travel on the designated routes. Second,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 426 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Four alternatives (2, 4, Modified 4 and 5) analyze reallocating

Management Area 10 C (designated routes only) to

Management 10 (B) (open) in varying degrees. It is outside

the scope of this analysis to consider changes in motorized

access within in any areas not designated as Management 10

(C).

Murphy, Patrick (Wild and Scenic River Designation, 1,265 acres) Tahkenitch 

and Ten Mile are not designated as “Wild and Scenic” 

http://www.rivers.gov/rivers/oregon.php

Management Area 10 (J), as described in the 1994 Dunes

Plan, are "Proposed Wild and Scenic Rivers" (Dunes Plan, p.

III-48). The Dunes Plan states the goal for this Management

Area as maintaining the river's free-flowing characteristics; to

protect and, if practicial enhance the outstandly remarkable

values of the river and its immediate environment (Dunes

Plan, Chapter III, page 48). 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 427 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Murphy, Patrick All other trails: All trails classified as 10c shall be reviewed for 

non-native and/or invasive vegetation and reallocated to a 10 

b designation as appropriate.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Murphy, Patrick The Forest Service is quick to point out potential limitations of 

the OPRD study, yet transparency is severely lacking within 

their own work. Errors are inherent in the context of their 

study, yet the Forest Service does not acknowledge the errors 

in the data they use.[...]The Forest Service survey contains 

inherent potential for errors and uncertainty that they do not 

acknowledge. They would benefit from more transparency 

about the methods they used and discussion about the 

potential for errors in the data that they used.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 428 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 429 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Nero, Kim I would like you to please keep the Oregon Dunes open to 

OHV

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has four

alternatives to complete trail and area designation within

Management Area 10C.

Neyens, Loren We would like these trails and areas to stay open. Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Nichols, Gary reducing available area will at first lead to severe use and 

overcrowding of the remaining area and then as people 

become disenchanted, will take their recreation elsewhere, 

causing a severe economic change to the business 

communities close by.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 430 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 431 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Nichols, Marcia The agency failed to coordinate with affected counties in this 

EIS and the 1994 Dunes Plan. I want to ensure the ODNRA is 

following administration directives and has actively considered 

designation of federal and non-federal cooperating agencies in 

t he preparation of analyses and documentation required by 

the National Environmental Policy Act (NEPA). I also want to 

ensure that Federal agencies actively participate as 

cooperating agencies in other agency's NEPA processes.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Nichols, Marcia As a 25-year resident of Florence, OR, I have concerns that 

this restriction would kill the majority of the tourism in the 

area. This is the main economy of the affected coastal towns.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 432 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Nichols, Marcia The Forest Service should create a new or modified planning 

process with alternatives that might help the agency and the 

public to meet the current purpose and needs of the resource 

and community.

Pleasae see response #123 for a discussion of the

development of alternatives.

Nottingham, Gary I seem to favor your Alternative #5. Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 433 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Nottingham, Gary remember the trails are a challenge to some of us and give us 

a sense of accomplishment just to be able to ride on them. 

Open sand is not where we prefer to ride.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Numm, Carolyn What is not understandable is why the FS

wants to protect an invasive grass that is killing the dune

The intent of the project is not to protect non-native or invasive

species. "Non-native, invsive species, such as Scotch broom

and and/or European beachgrass do not need to be protected

from impacts by OHVs" (DEIS and FEIS, Chapter 1). Several

reallocations from MA 10 (C), wherein vegetation is to be

protected by restricting OHVs to designted routes only, are

proposed in areas of predominantly non-native vegetation to

make those areas open to OHV riding. 

Olivier-Price, Andrea My Husband and I both feel that taking away the Dunes from 

our family's is a hugh mistake.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 434 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Pawlowski, Brent Please keep the current Oregon Dunes and trail network open. 

That is keep open the dunes and the entire 100-some miles of 

“trail” network.[...]FS wants to try to take away publics lands 

by playing the endangered species card.[...]I would like to 

give feedback on the proposal that I like the best. I like 

“Alternative 6” that is, keep all trails open.

Thank you for your comment.

Pawlowski, Brent The “trails” simply are areas where the invasive beach grass is 

kept at bay when Us citizen, tax payers, and visitors use the 

area.

Areas of user-developed routes in MA 10 (C) occur in a

variety of vegetation in the ODNRA including plantations,

native vegetation and areas dominated by non-native

species. Please refer to Response #142 for a discussion on

existing vegetation in MA 10 (C) and its relationship to open

sand at the time the ODNRA was established.

Pawlowski, Brent Perhaps the Forest Service could start a program to remove 

the invasive species around the dunes and allow the dunes to 

move in the natural way.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Peters, Sarah Routes R2 and R3 appear to be redundant with the South 

Jetty OHV Trail and Routes R5

and R6 are semi-redundant with each other. Route R6 would 

avoid interaction (and

therefore unnecessary temptation) with the multitude of user 

created routes that spur off

of R5.

Please refer to Table 26, Proposed Routes and Area

Rationale for a discussion of the rationale for proposing

designated routes and changes in reallocation from MA 10 (C)

to MA 10 (B).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 435 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Peters, Sarah Route R8, while not part of the proposed or preferred 

alternatives, does not meet the intent

of 10C areas.[...]It is a long loop route with no apparent 

purpose of getting from A to B. This[...]If the purpose is to 

connect to the beach it should be done with a more direct 

route

(as seen in the most northern portion of this route before it 

turns south) at top and bottom

of this area, with no designation of the middle portion of the 

route that parallels the open

sand/beach area.

Proposed designated routes, as directed by the 1994 Dunes

Plan, should connect open riding areas or connect open riding

areas to the beach. The routes proposed in this project are

not circuitous. R8 in the Umpqua riding areas is a connection

from open riding to the beach. It continues to parallel the

beach before returning to open sand in order to accommodate

the number of riders in the Umpqua riding area desiring to ride

to the foredune, park and visit the non-motorized beach. This

route exists on the ground and would alleviate congestion and

prevent the foredune from becoming an over-crowded parking

area for beach visitors accessing the area by OHV. Please

refer to the rationale for R8 on page 45 of the DEIS and FEIS.

Peters, Sarah Route R10 should not be designated, as it appears on this 

map to be redundant with the

Hauser OHV Trail[...]The asserted need is to remove 

congestion on Hauser, but since this

section of Hauser appears, again, by this map, to go through 

a 10B riding area, comprised of open sand, congestion seems 

unlikely to be a valid concern.

Please refer to Table 26, Proposed Routes and Area

Rationale for a discussion of the rationale for proposing

designated routes and changes in reallocation from MA 10 (C)

to MA 10 (B).

Peters, Sarah Wildlands specifically has concerns about the large area redesignations from 10C to 10B,

including A2 in the north riding area and A16 in the middle 

riding area.

The boundary line separating the Umpqua riding area and the

Tenmile Research Natural Area (RNA) is posted as closed to

OHVs with signs on wooden posts. During field observations

over that last eight years, this line of staggered signing

through the open sand of MA 10 (B) has been an effective

deterrent to OHVs. The only user-created route entering the

RNA from the area south of A16 has been barricaded at the

Coos/Douglas County line and has been monitored for the

past four years.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 436 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Peters, Sarah Redesignation of A1 as MA 10B will make closure of user 

created routes in the remaining 10(c)

zone expensive and enforcement of those closures nearly 

impossible.[...]The amount of “open”

riding area provided by this re-zoning is minimal, and will only 

increase the likelihood of

violations of the 10C closures adjacent to this area.[...]we 

particularly disagree with the redesignation

of area A1 from 10C to 10B. This area would be a prime 

expansion area for snowy plover, and should be treated as 

such in the selected alternative.

The proposed A1 reallocation is a swath of historically open

sand. It is currently relatively open, with areas of non-native

vegetation including scotch broom and European beachgrass.

The edges of the proposed reallocation are more densely

vegetated, and lined with shorepine. Very few user-created

trails enter the dense vegetation. This natural barrier will aid in

enforcement. The area is heavily trailed and provides a trail

riding experience for riders as well as connecting open riding

areas.

Peters, Sarah

Re-designation of A2 as an open riding area will have serious 

impacts to the continued health

and recovery of snowy plover and should not be part of any 

preferred action.[...]it should be zoned as 10E, snowy plover 

habitat,[...]this was not the intent of the original Dunes Plan 

for which Fish and Wildlife Service issued a concurrence in 

1994,[...]Formally changing the management direction of this 

area to reflect existing management practice likely will 

permanently prevent snowy plovers from expanding into this 

area, at a time when their population still struggles to recover.

[...]At a minimum, this re-designation of A2 should not adjoin 

any area presently designated as

snowy plover critical habitat or management area 10E, which 

appears to be satisfied by the

current re-zoning proposal.

The northern portion of the proposed A2 reallocation would tie

into an existing designated route along the southern edge of

the South Jetty Road. OHV use of the designated route

accessing the beach from the Goose Pasture staging area will

continue just south, and visible from the South Jetty Road.

Peters, Sarah recommend closure of the spur that continues from the 

coastguard North OHV trail into the heart of this area.

The small portion of the Breach route that extends west to the

beach is proposed for seasonal closure from September 16

through March 14 to minimize conflict with wintering snowy

plover habitat in all the action alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 437 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Peters, Sarah We support the closure of the Breach OHV Trail that dead 

ends into the Siltcoos Breach snowy

plover protected area[...]Closure of the breach trail, adjacent 

to snowy plover wintering habitat, is a critical element

for protection and expansion of snowy plover. We ask that the 

chosen alternative at a

minimum include this closure.

Closure of the portion of the Breach designated route west of

its intersection with the Coast Guard designated route is

included in Alternatives 2 through 5.

Peters, Sarah recommend relocating the existing portion of Coastguard 

North OHV trail so that

the trail does not join this sensitive area.

Designated routes within MA 10 (C) are not precluded from

vegetated areas. The Dunes Plan directs that OHVs be

permitted on designated routes in order to protect vegetated

habitats (Dunes Plan, p. III-20).

Peters, Sarah The Forest Service should take this opportunity to formally 

manage Siltcoos Breach and Siltcoos

Beach as a single management unit protected for snowy 

plover recovery

Changes to Management Area 10 (E) Snowy Plover Habitat

are outside the scope of this project. This project addresses

only Management Area 10 (C) where OHVs are permitted on

designated routes only.

Peters, Sarah re-zone areas from 10(c) to a more protective designation if 

trails are not being designated in the area.

Areas of MA 10 (C) not designated as routes are closed to

motorized vehicles. This is as restrictive as any other

management area closed to motorized vehicles.

Peters, Sarah Area A4 rezone appears a bit arbitrarily drawn and might be 

difficult to enforce[...]it will still be difficult to mark

this re-zone as open when the un-rezoned portion, by looking 

at the underlying topography,

appears to contain a large number of existing user created 

trails. It is difficult to imagine

that the existing user created routes in the un-rezoned portion 

of 10C will not continue to be used when it is sandwiched 

between two open riding areas.

The southern portion of the A4 reallocation is a vegetated

area directly north of the Horsfall Campground and

surrounded by open riding to the north and east. On the west

side, the area is tied into an existing designated route. The

north portion of the A4 reallocation also consists of a

vegetated area surrounded by open riding to the east and

south and anchored to an existing designated route. The

areas are not arbitrarily drawn, but encompass

small vegetated areas. If reallocated, these areas would not

need signing nor route maintenance and would become part

of the surrounding open riding areas.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 438 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Peters, Sarah Re-zoning of A5 will lead to continued resource damage and 

enforcement problems.[...]Changing this area

from 10C to open riding will create an extension of the 

unregulated Riley Ranch county property

to its north and will encourage riders from that property to 

violate the protective closures along Beale Lake.[...]The 

impact of a re-designation adjacent to Beale lake natural area 

and wetland has not

been adequately assessed.[...]re-designation of this to an 

open riding area will only increase the likelihood

that these violations will continue to occur.[...]table 41, p. 

122. This table should also take

into account the distance to associated wetlands.[...]If this 

designation occurs, then a specific plan should be 

implemented to prevent illegal

motorized use in the lake and its associated wetlands.

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Peters, Sarah Port Orford Cedar in the Beale Lake 10F area should be 

protected from p. lateralis by ensuring no motor vehicles enter 

the area.

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 439 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Peters, Sarah The Forest Service has failed to show how these area 

redesignations and trail designations

will minimize impacts, in compliance with ORV Executive 

Orders 11644 and the Travel

Management Rule, to wildlife, water resources, vegetation, 

and conflicts with other users of

the Dunes.

Please refer to FEIS, Chapter 3, Environmental

Consequences

Peters, Sarah It is particularly unacceptable to re-designate areas containing 

a high percentage of native

vegetation to be open riding areas.[...]This is particularly

true for the 92 acres proposed in the preferred alternative 

(see table 22 p. 53 of the DEIS),

causing a “High” likelihood of spreading invasive species to 

the 92 acres of native

vegetation in Alternative 4.[...]Any areas where there would 

be a “high” impact to native

vegetation, such as A16 and A4 or “moderate” impact, as in 

A5, A16, A15, and A1, should

also not be designated. See table 29, p. 80.[...]Adverse 

impacts to native plant communities must be minimized by 

area and trail designations, and re-allocating these areas does 

not meet that threshold.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 440 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Peters, Sarah areas of mixed native and invasive plant communities should 

be targets in future decision for restoration and removal of 

invasive plants so that native plant communities can expand.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Peters, Sarah Please include an enforcement plan, with potential triggers for 

closure if violations occur,

in the final EIS and ROD[...]if closures are continually 

ineffective, the Forest Service should have a plan in place to 

adapt its strategy to protect closed areas by providing, 

through this EIS, for automatic adjustment of open riding 

boundaries away from sensitive areas, closure or re-routing of 

trails where frequent and repeated violations occur, increase 

of law enforcement presence, and a process to increase fines, 

particularly for repeat violators

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 441 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 442 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Peters, Sarah Designated routes should not be redundant or circuitous, and 

impacts should be minimized

in compliance with the ORV Executive Orders 11644 and the 

Travel Management Rule, 36

CFR 212. In addition to requesting that all route designations 

meet the specific

requirements to minimize impacts to forest resources

Proposed designated routes, as directed by the 1994 Dunes

Plan, should connect open riding areas or connect open riding

areas to the beach. The routes proposed in this project are

not circuitous. R8 in the Umpqua riding areas is a connection

from open riding to the beach. It continues to parallel the

beach before returning to open sand in order to accommodate

the number of riders in the Umpqua riding area desiring to ride

to the foredune, park and visit the non-motorized beach. This

route exists on the ground and would alleviate congestion and

prevent the foredune from becoming an over-crowded parking

area for beach visitors accessing the area by OHV. Please

refer to the rationale for R8 on page 45 of the DEIS and FEIS.

Peterson, Jay The purpose and need should have been broadened to 

address the legislative intent of the original National 

Recreation Area Act.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Phelps, Elaine Please don’t take this family opportunity away from us. Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 443 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Phillips, Jody All I ask is to look at these 10C areas that are clearly full of 

junk grass and open it back up to have us ride in it.[...]A 

healthy ONDRA is open sand, not vegetation.

Non-native invasive plan species are present throughout most

of the Oregon Dunes NRA. From area to area they can vary

in terms of their local dominance and to what degree they

potentially displace native species and/or disrupt natural

processes. An existing invasive plan database provides

mapped locations for a number of species that have been

classified as Noxious by the State of Oregon, or are

considered to be highly invasive. Included are European

eachgrass, scotch broom, Portuguese broom and gorse

(Chapter 3, FEIS).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 444 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Phillips, Jody The original 1979 Act created an Advisory Council. We must 

bring this back or some form of it with enough teeth that the 

USFS does not act alone in any final decision.[...]We need to 

coordinate with the Counties on any decisions and re-instate 

the Advisory Council.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 445 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Phillips, Jody Of the Alternatives, Alt 5 should be the starting “Book End” 

and opening up all 10C to 10B should be the ending ‘Book 

End”. Any area that is clearly non-native vegetation should be 

reallocated to 10B.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Phillips, Jody Please refer to FEIS, Chapter 3, Botanical Resources where it

states, "Non-native invasive plants are spread by wind, water,

animals, and people. one mechanism of plant spread is

vehicles that pick up sees and plant parts on their tires, body,

and chassis, transporting them to other locations where they

drop off and potentially start new infections. No specific

information was found that looks at the role OHV's may have

in the spread of invasive plants in the ODNRA. Else where, it

has been shown that vehicles do spread invasive plants, and

that potential to transport seed increases when the vehicle

travels off-road, and that the amount of seed that is carried by

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 446 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

There are several flaws in the DEIS. On page 77 and Page 

136 the statements that OHV affects are limited in killing 

grass.[...]Any research on the positive sides of a family sport 

where all family members participate. Again misleading. Both 

sides of the equation must have research. All research is 

negative to OHV.[...]It doesn't say non-native, but take a look 

at page 70 of DEIS. "Shore pine, planted on previously unstabilized land, has grown into forest that has little of the 

understory plant diversity that would be expected in natural 

woodland."[...]It also, in a roundabout way, talks about how 

OHVs can remove invasive species (page 71). "In portions of 

the ODNRA where OHV use is common, vegetation may be 

largely absent within the open sand areas with the exception 

of existing tree islands and hummocks of vegetation that form 

in areas that are inaccessible to OHVs." Again, misleading. 

Which is it? Again, the deflation plane is an exception because 

it is underwater most of the year so we do not go in there.

the vehicle increases in wet conditions (MSU 2011). Because

sandy soils do not stick to vehicles in the same way as finer

loam or clay, the results of these studies may not be directly

appliciable to conditions in the project area, but some seed

transport by vehicles cannot be ruled out as well as the

potential to introduce seed from other areas outside of the

ODNRA where the vehicle may have been. The potential to

introduce or spread invasive plants by vehicle and what

degree of impact that has on other resources can be ranked.

Designating areas of largely native vegetation to open OHV

use would have the greatest risk of impact, followed by new

construction of designated routes through native vegetation

within Management Area 10 (C), designating an existing userdeveloped trail within native vegetation, and least impacting,

designating a user-developed trail through non-native

vegetation or opening an area of non-native vegetation to

open OHV use." It also states, "Intensive OHV use can reduce

or eliminate the colonization of invasive European beachgrass

and an argument could be made that reallocating areas from

Management Area 10 (C) to 10 (B) may provide some control

of this species. To be effective however, high frequency and

duration of use would need to be maintained over an entire

area. Because areas proposed for reallocation were selected

for their potential to provide trail riding opportunities, use

patterns would not likely result in any real reduction in

European beachgrass."

Phillips, Jody If Alternative 5 is all we get then the extra 3500 acres needs 

to mitigated. The currently closed dunes between Spinreel 

north to Douglas/Coos County line should be seasonally 

opened during the winter for this mitigation. This would bring 

huge crowds and an economical boost to the counties helping 

to offset the typical seasonal summer months.[...]Our 

economy depends on the health and wellbeing of the ODNRA.

 

Opening additional areas to motorized vehicles is outside the

scope of this project. On November 9, 2005, the Travel

Management Rule was published in the Federal register. Prior

to the Travel Management Rule, National Forests were open

to motorized travel unless designated closed. Now, under the

Travel Management Rule, National Forests are closed to

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 447 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

motorized travel unless designated open. The Oregon Dunes

National Recreation Area currently has about 34 miles of

designated trails and about 5,930 acres of designated areas

for open motorized travel. As the Siuslaw National Forest

developed its 2009 Travel Management Plan, it became

apparent that since not all the MA 10 (C) routes had been

designated, some areas within the motorized portions of the

ODNRA were largely inaccessible. 

Both the 1979 and 1994 Dunes Plans allocated lands for OHV

travel on designated routes, however two issues have resulted

in what we have today. First, prior to the 2005 Travel

Management Rule, a Subpart b order was required to close

Management Area 10 (C) to motorized cross-country travel

and allow motorized travel on the designated routes. Second,

other than the 34 miles of routes designated, no others were

designated. Without a Subpart b order or additional route

designation, motorized travel was not enforced on

undesignated routes.

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Four alternatives (2, 4, Modified 4 and 5) analyze reallocating

Management Area 10 C (designated routes only) to

Management 10 (B) (open) in varying degrees. It is outside

the scope of this analysis to consider changes in motorized

access within in any areas not designated as Management 10

(C).

Phillips, Jody The National Environmental Policy Act provides the Forest

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 448 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Why can’t there be a Supplemental EIS? The 1994 Plan is 

flawed and outdated. A supplemental EIS could and would 

address the concerns of restoration, concerns of the Counties 

and look at ways to better manage the ODNRA to work 

together to open up sand for everybody. It seems that 

nobody is going to be happy anyway. It is time to do the right 

thing for the health of the communities and the ODNRA as a 

whole.[...]The “experiment’ to see restoration on the north 

side of Spinreel Hill and the effects of OHV on keeping the 

grass at bay after shore pine removal. Verbally we hear about 

it but no documentation which I feel is intentionally miss 

leading. Also look at Sand Lake![...]Sand camping needs to be 

revisited. There is not enough camping in the nonnative 

vegetation to help stop the wind... need more group sites. I 

realize this is not in the scope but needs to be revisited.[...]

We also should be able to ride on Horsefall road between the 

campground and the beach campground. Again, not the scope 

but this is a safety issue to reduce the traffic on Hauser Sand 

Road. This is such a simple request and would bring back 

some good will to the USFS from OHV users. I refuse to 

believe it cannot be done.[...]If the 1994 Plan is what we have 

to live with then we need a supplemental EIS and reset the 

course and priority for the ONDRA.

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 449 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 450 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Phillips, Jody Directly in the DEIS, on page 62 under trail riding experience 

it states that we have 46% of the ONDRA to ride on. Again, 

this is extremely misleading, unfair and completely inaccurate. 

For someone to read this DEIS that does not understand the 

boots on the ground that would lead a non-OHV person to 

believe we have our fair share. Zones 10C (4,455 acres 15%), 

10G (2,540 acres 9%) and 10L (374 acres 1%) are all closed 

unless signed to be open. They are accounting for these areas 

in the percentage of areas we can ride. The wetlands 10G 

designation we are not allowed to ride in. In reality we have 

only, at best, 25% of the entire ODNRA to ride on which is 

10B with some designated trails that might account for 10 

acres only.

The DEIS does not describe 46% of the ODNRA as open to

cross country OHV travel.

The DEIS and the FEIS state, "In 1994, the current Dunes

Plan was adopted, zoning 46% of the ODNRA as open to

OHV use to various degrees. This number includes MA 10(B),

where open riding is permitted, as well as Management Areas

10(C), 10(G), and 10(L), where OHV use is permitted on

designated routes only." (FEIS, Chapter 3, Recreation,

Cumulative Effects. The 11 management areas and their

primary emphasis and associated acres were provided in the

DEIS, Chapter 1, Background, p. 8 and can be found in the

FEIS Chapter 1, Background. Management area acreage

percentages that are included in the 46% that allow OHV use

to varying degrees are as follows; MA 10(B) Off-Road Vehicle

Open (21%), MA 10(C) ORV on Designated Routes (15%), 

MA 10(G) Wetlands Emphasis (9%) and MA 10(L) Noise

Control Buffer (1%).

Phillips, Jody Either that or stop this 10C process and start the planning for 

the new 2014 Plan that is way overdue.

At one time the Siuslaw national Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 451 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Phillips, Jody Restoration is first and foremost and should remain that way. Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Phillips, Jody DEIS Input-Trail Designation and Re-allocation Suggestions

South Riding Area: reallocate small area north of county land 

near Riley Ranch from MA 10 C to MA 10 B

•What are opportunities/constraints to access Beale Lake?

•Would like to see some sand-camping with vegetation to 

block wind.

•Like route 13.

Middle Riding Area: designate route in last finger

North Riding Area: Provide foot access to Cleawox Lake, 

Reallocate Areas north of R3 and north of A1. Reallocate area 

south of sand camps 1, 2 and 3.

The small area near Riley Ranch was not considered for

reallocation due to wet conditions, thick vegetation and little

evidence of use. Closer examination of the 1994 Dunes Plan

maps of management areas, a narrow strip of MA 10 (C) lies

along the western edge of the Coos County property and

connects the open riding areas, paralleling the 430 designated

route. This has been clarified on the South Riding Area maps.

Reallocations north of R3 and north of A1 were considered but

not proposed based on limited use and existing vegetation.

The area south of sand camps 1, 2, and 3 is proposed for

reallocation in Modified Alternative 4.

Access to Beale Lake will be unchanged through this process.

Foot access is not prohibited in any areas of MA 10 (C) and

MA 10 (B).

Price, Dyanne Alt #4 - i think is the best for all Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 452 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Price, Dyanne Would like to see trails on the fingers - stay open- O.K. "just 

let us get from one finger to another."

 

Continued use by OHVs on trails that cross the fingers is not

sustainable ecologically. In addition, these trails cannot

provide sustainable, long term, challenging recreational

opportunities sought after by the public. Historic use at

Banshee Hill confirms this. The initial route across Banshee

Hill was narrow and challenging requiring skills and equipment

only a few people possessed. As use continued and

equipment became more powerful, the trail widened, down

cut, undercut native vegetation, and became less steep with

the sand being pushed downhill. Ecologically, this has

undercut and killed additional native vegetation and provided

opportunities for new non-native vegetation growth. The

recreation experience is no longer as challenging and riders

have begun to develop new, more challenging trails adjacent

to Banshee Hill. Closing Banshee Hill is not practical. 

Designating trail opportunities on other fingers and

forthcoming associated challenging user created trails does

not simplify OHV management. This cyclic pattern of

continuously seeking challenging trails is not sustainable long

term. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 453 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Rehg, Charmaine Do not open any additional areas of the Oregon Dunes 

National Recreation Area to motorized use. Also, and long 

overdue, close all illegal, unauthorized off-road vehicle routes.

Two areas are managed primarily for OHV use at the Oregon

Dunes. Those areas are called Management Area 10 (C)

wherein OHVs are permitted on designated routes only and

Management Area 10 (B), open riding. This project addresses

only Management Area 10 (C). Changes are proposed to MA

10 (C), but no changes are proposed to expand areas

for OHVs into areas that are not currently managed for OHV

use to some degree. The rationale for reallocating areas of

MA 10 (C) to MA 10 (B) includes the predominance of nonnative vegetation. Please refer to Chapter 2 of the DEIS and

FEIS for more information on the rationale for proposals for

reallocations to open riding.

Reichgott, Christine Revise management direction for area A4 to avoid impact to 

areas where shore pine/slough

sedge associations are present; or pursue the management 

strategy under Alternative 3 for this

area.[...]Revise management direction for area Al6 to avoid 

impact to the 19 percent of the. reallocation area that is 

mapped as native vegetation; or pursue the management 

strategy under Alternative 2 for this area.

The Forest Service developed project design criteria to be

used as part of all of the action alternatives. Please refer to

Botany Project Design Criteria on page 62 of the FEIS.

Barriers or other methods may be employed to discourage off

-trail OHV use in areas of native vegetation.

Reichgott, Christine We recommend that the FEIS discuss manqgement 

triggers/thresholds and measures (herbicides, biological 

controls, mechanical removal, etc.).

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 454 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Reichgott, Christine we believe that recommendation 2 above would substantially 

address the risk of invasive plant infestation by reduCing the 

number of acres under MA 10 (B).

No alternatives seek to reduce the acres in Managment Area

10 (B).

Reyes, Don I personally think the solution is to educate all visitors of the 

rules and regulations of the dunes and enforce them. Not to 

close the land and restrict all access.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 455 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Richardson, Cary Please do not close any more of our dunes, in fact, I would 

encourage to open more back up to get us closure to the 90% 

we used to have.[...]Our system of dunes is already choked 

down to 21% access from what used to be 90+%

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 456 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 457 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 458 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 459 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 460 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Richardson, Cary More closures will only bring negative results, including: more 

and more riders on less ground will cause more and more 

accidents, allow non-native plant species to continue to 

proliferate, encourage riders to seek other areas to ride that 

are less crowded.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety. 

Richardson, Erin don't close any so-called illegal trails.[...]Our system of dunes 

is already choked down to 21% access from what used to be 

90+%.[...]I would encourage to open more back up to get us 

closure to the 90% we used to have.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 461 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 462 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 463 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 464 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 465 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Richardson, Erin riders seeking other less-crowded areas will take revenue 

away from the local economies

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 466 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Richardson, Erin more and more riders on less ground will cause more and 

more accidents,[...]more accidents give more ammunition to 

fun-haters to close more dunes,

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 467 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Richardson, Erin allow non-native plant species to continue to proliferate Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Richardson, Erin encourage riders to seek other areas to ride that are less 

crowded.[...]and put additional stress on the other riding 

areas they discover.

Rider density can be a partial derminant of rider safety, but it

is not possible to reliably and accurately predict how any of

the alternatives being considred will affect visitation, and thus,

rider density. By its nature, OHV riding can be a high risk

outdoor recreation activity. Given the numerous rider safety

vriables over which the Forest Service has no control and the

inability to accurately predict future rider density, the Forest

has proposed only alterntaives that it believes have a high

potenital for rider safety. (DEIS, FEIS, p. 14)

Riders Dunes, Save These so called “user created trails” have been there the 

whole time and the planted areas have grown up and around 

them.

Areas of user-developed routes in MA 10 (C) occur in a

variety of vegetation in the ODNRA including plantations,

native vegetation and areas dominated by non-native

species. Please refer to Response #142 for a discussion on

existing vegetation in MA 10 (C) and its relationship to open

sand at the time the ODNRA was established.

Riders Dunes, Save Yes we know that trails have been made thru native areas 

(tree islands) in some areas and we agree that these need to 

be closed.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 468 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Riders Dunes, Save In the North area we have the South Jetty designated route 

that is a creek approximately 8 months out of the year. That 

is the outlet from Cleawox Lake and is in a planted plantation, 

not a NATIVE area, so this whole 10c area should be reclassed to 10b.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Riders Dunes, Save Economics - in the working groups comments that 

acknowledged 62 million dollars spent annually from OHVer’s 

(Oregon State study), but in the DEIS you say 2.5 million? 

This is a flawed discrepancy.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 469 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 470 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Riders Dunes, Save The original Act created an Advisory Council and for some 

unknown reason this advisory council just disappeared along 

with a few other councils to do with off-roading. We need an 

advisory council brought back so the public can have say in 

how the ODNRA should look, not just the USFS.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 471 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Riders Dunes, Save The Counties (Lane, Douglas & Coos) were not included in 

these meetings. They should have been consulted at each one 

of the working groups meetings and included in the draft DEIS 

process.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Riders Dunes, Save Restoration of the dunes - We keep hearing that we need to 

finish this 10c process before we can talk about restoration. If 

we restored what was once open dunes in the 10c areas, we 

would not be working on designated routes because they 

were all once OPEN sand....until the USFS decided to plant.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 472 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Riders Dunes, Save Acreage data, DEIS page 68 says we have 46% of the ODNRA 

to ride on.

The DEIS does not describe 46% of the ODNRA as open to

cross country OHV travel.

The DEIS and the FEIS state, "In 1994, the current Dunes

Plan was adopted, zoning 46% of the ODNRA as open to

OHV use to various degrees. This number includes MA 10(B),

where open riding is permitted, as well as Management Areas

10(C), 10(G), and 10(L), where OHV use is permitted on

designated routes only." (FEIS, Chapter 3, Recreation,

Cumulative Effects. The 11 management areas and their

primary emphasis and associated acres were provided in the

DEIS, Chapter 1, Background, p. 8 and can be found in the

FEIS Chapter 1, Background. Management area acreage

percentages that are included in the 46% that allow OHV use

to varying degrees are as follows; MA 10(B) Off-Road Vehicle

Open (21%), MA 10(C) ORV on Designated Routes (15%), 

MA 10(G) Wetlands Emphasis (9%) and MA 10(L) Noise

Control Buffer (1%).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 473 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Riders Dunes, Save All of 10c needs to be changed to 10b in Non Native areas, 

(i.e. :) Plantations, Scot’s broom & European beach grass 

areas

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Riders Dunes, Save We either need a supplemental EIS to reset the course of the 

ODNRA or completely stop this process and start on the 2014 

plan.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 474 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 475 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Riders Dunes, Save Flawed Data & Statements - 90% of the trails you want to 

close are thru NON-NATIVE planted plantations and invasive 

species, not native areas. As stated by a FS employee “Offroaders are usually free to go anywhere they want on open 

sand, but in wooded areas they’re expected to stay on trails 

that protect native species” says Michele Jones. “Plants & 

trees threatened by off roaders are Douglas Fir, Sitka Spruce, 

evergreen huckleberry, Hookeri willow, slough sedge and 

Pacific silverwood”. This is only about 5% of the user created 

trails and we agree that this need to be closed.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 476 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Riley, Kelly I am writing to let you know about my concerns with the 

proposed revision to the Oregon Dunes National Recreation 

Area management plan, which would expand areas for offroad vehicle use.[...]the Forest Service should not revise the 

Dunes Plan to expand open riding areas.

The purpose and need for the project is designate routes and

areas in MA 10 (C). As directed by the Dunes Plan, MA 10

(C) allows OHVs on designated routes only. Areas of MA 10

(C), which are already managed for motorized use to some

degree, were found to be suitable for reallocation to open

riding. The intent of this project is not to protect non-native

vegetation. For the rationale for proposing reallocating areas

of MA 10 (B) to open riding as MA 10 (B), please refer

Chapter 2 of DEIS and FEIS.

Riley, Kelly OHVs should be limited to open sand, but some open sand 

must also remain non-motorized.[...]In addition, off-road 

vehicle users should not be "compensated" for a presumed 

loss of usage area, however illegal and unauthorized it may 

have been, with other areas of the dunes which have long 

been managed for use outside of motorized areas.

Open riding is limited to Management Area 10 (B), which

largely consists of open sand. The 1994 Dunes Plan, which

directs management of the Oregon Dunes NRA

(ODNRA), also permits motorized vehicles on portions of

vegetated areas known as Managment Area 10

(C). Motorized vehicle use is permitted to some degree on

approximately 46% of the ODNRA. This project does not

propose to alter the percentage of the ODNRA managed for

OHVs to some degree.

The remaining 54% of the ODNRA includes areas

of vegetation areas and open sand that are managed for nonmotorized recreation. Specifically, 7,830 acres are managed

as MA 10 (A), Non-Motorized Undeveloped. This project does

not propose to alter the percentage of teh ODNRA managed

as non-motorized.

Riley, Kelly Native vegetation and wetlands must be protected and 

safeguarded from motorized recreation.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 477 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Rish, Launi I’m writing to let you know I do not support in any way the 

alternatives in the DEIS and that the Forest Service need not 

to close any more area!

Thank you for your comment.

Rish, Launi Legal/safety – With the huge amount of closed trails proposed 

it will create bottlenecks at the little left trails thus seen in 

lawyers eyes as purpose full incompetence to create 

unneeded injury from the previous open areas’ that have 

worked well for years.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Rish, Launi Having open dunes and trails all in the same area makes the 

Oregon Dunes the best overall experience for sure! Having 

these trails closed will destroy the unique style over other 

dunes and having to go around everything will make our 

wonderful dunes boring to say the least. I love the tree shots 

and the trails can really help new riders get comfortable with 

certain aspects of riding.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Rish, Launi Economic impacts are sufficiently examined in the DEIS and

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 478 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Economic – As an out of state resident I will not go to the 

Oregon Dunes and spend my thousands of dollars per year on 

multiple visits if the proposed areas’ are closed.

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 479 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Rish, Launi • Enforcement – With the multiple fold drop in enforcement 

funding the multiple fold increase in closed areas’ will not 

have one 1/10th the needed man power to enforce those 

closed areas’.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 480 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 481 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Roach, Gary It is my opinion that the present trail network at the middle 

riding area be largely maintained with new trails strongly 

discouraged. also it is my opinion that many of the parallel 

trails could and should be closed. At Winchester it would be 

nice to have a connecting trail between the fingers.

 

Continued use by OHVs on trails that cross the fingers is not

sustainable ecologically. In addition, these trails cannot

provide sustainable, long term, challenging recreational

opportunities sought after by the public. Historic use at

Banshee Hill confirms this. The initial route across Banshee

Hill was narrow and challenging requiring skills and equipment

only a few people possessed. As use continued and

equipment became more powerful, the trail widened, down

cut, undercut native vegetation, and became less steep with

the sand being pushed downhill. Ecologically, this has

undercut and killed additional native vegetation and provided

opportunities for new non-native vegetation growth. The

recreation experience is no longer as challenging and riders

have begun to develop new, more challenging trails adjacent

to Banshee Hill. Closing Banshee Hill is not practical. 

Designating trail opportunities on other fingers and

forthcoming associated challenging user created trails does

not simplify OHV management. This cyclic pattern of

continuously seeking challenging trails is not sustainable long

term. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 482 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug While not specifically addressed in the purpose and need of 

the Draft EIS, the Board wishes to also direct your attention to 

Section 12 of the Oregon Dunes National Recreation Area Act 

(P.L. 92-260) wherein the Secretary was to establish an 

advisory council :

"The Secretary shall establish an advisory council for the 

Oregon Dunes National Recreation Area, and shall consult on 

a periodic and regular basis with such council with respect to 

matters relating to management and development of the 

recreation area. The members of the advisory council, who 

shall not exceed fifteen in number, shall serve for individual 

staggered terms of three years each and shall be appointed 

by the Secretary as follows:

(i) a member to represent each county in which a portion of 

the recreation area is located, each such appointee to be 

designated by the respective governing body of the county 

involved .... " id. at Section 10 (16 U.S.C. §460z-10).

The Board of Commissioners request that as a separate 

nondiscretionary action, the Secretary establish the advisory 

committee. In the absence of the Section 10 committee, the 

Forest Service is arbitrarily avoiding the consultation 

requirements, and benefits, of the Act.[...]Douglas County 

requests that the committee include two members which are 

appointed by the Board of County Commissioners of Douglas 

County. As you initiate the new planning process in 2014, the 

advisory committee would be invaluable in helping to define 

the scope of the analysis, identifying relevant issues, and, in 

assisting in development of alternatives.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective June 10, 1977,

in accordance with the provisions of the Federal Advisory

Committee Act (FACA) of 1972 (Public Law 92-463). The

Forest is not against establishing an Advisory Committee

provided that we have a compelling reason to have one

established. 

The purpose of an advisory committee would be to provide a

forum for a diversity of interests and thoughts in order to help

inform the management the Oregon Dunes. We already have

a strong history of working with interested groups across the

Forest and are successful in bringing a diversity of interests

and thoughts into the management of the Oregon Dunes. The

Working Group is a good example of how the Forest works

informally to help inform our management of the Oregon

Dunes and this has been quite successful. The Working

Group was assembled in 2009 and comprised of fourteen

people with diverse and varied interest in the Dunes. The

group produced an independent report with suggestions for

route designations in Management Area 10.

The success of our current partnerships and our history of

collaboration indicates that there is not a compelling reason to

establish an Advisory Committee at this time, but could be

reviewed in the future if circumstances change. Ultimately,

whether or not to establish an Advisory Committee is outside

the scope of the decision on the Designated Routes project. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 483 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug Dune restoration, specifically control of the beach grass (e.g. 

Amophila arenaria) that originated with artificial plantings.[...]

We understand that the special off-road vehicle ad hoc 

committee raised this issue and recommended that this be a 

separate alternative. We, likewise, recommend that this 

recommendation be incorporated into the final plan.[...]beach 

grass is a driving force in the changing plant communities and 

the rider access, the impacts of beach grass encroachment on 

transportation/rider access and strategies to control beach 

grass should be addressed as environmental impacts as well 

as connected and cumulative actions.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Robertson, Doug The control of this vegetation was a focus of the original Act 

and one we believe can be partially addressed through the 

management of off-road vehicle use.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

Robertson, Doug Further, it is important to recognize that access to the 

recreational opportunities within the Oregon Dunes NRA is a 

critical element and foundation of the economy of the 

Winchester Bay- Reedsport area and Douglas County as a 

whole. Over the years, as fishing and logging have been 

adversely impacted, ATV riding has increased in economic 

importance. Maintaining a diversity of riding opportunities is a 

critical aspect of providing the recreational opportunities 

envisioned when the Oregon Dunes NRA was enacted.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 484 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 485 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug maintain the diversity of recreational riding opportunities. 

Therefore we request that the recreation opportunities on the 

upland (forested) portion of the Middle Riding Area be open 

subject only to limitations necessary to address safety issues.

 

Continued use by OHVs on trails that cross the fingers is not

sustainable ecologically. In addition, these trails cannot

provide sustainable, long term, challenging recreational

opportunities sought after by the public. Historic use at

Banshee Hill confirms this. The initial route across Banshee

Hill was narrow and challenging requiring skills and equipment

only a few people possessed. As use continued and

equipment became more powerful, the trail widened, down

cut, undercut native vegetation, and became less steep with

the sand being pushed downhill. Ecologically, this has

undercut and killed additional native vegetation and provided

opportunities for new non-native vegetation growth. The

recreation experience is no longer as challenging and riders

have begun to develop new, more challenging trails adjacent

to Banshee Hill. Closing Banshee Hill is not practical. 

Designating trail opportunities on other fingers and

forthcoming associated challenging user created trails does

not simplify OHV management. This cyclic pattern of

continuously seeking challenging trails is not sustainable long

term. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 486 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug Based on the current proposed alternatives, the Board 

supports the adoption of Alternative 5 as it is the most 

consistent with the plans and policies of Douglas County.[...]

the Board found Alternative 5 as it is the most consistent with 

the plans and policies of Douglas County. It has come to our 

attention that this may be taken out of context. While 

Alternative 5 is the best fit among the proposed alternatives, 

the Board believes that none of the current alternatives meet 

the objectives of the Act or the policies and plans of Douglas 

County. The Board believes that no action should be taken 

until the matters can be examined in a comprehensive 

planning process that reexamines the land management plan 

and the land allocations therein.

The proposed action alternatives meet the objectives of H.R.

8763 (the Act).

H.R. 8763, which established the Oregon Dunes National

Recreation Area "to provide for the public outdoor recreation

use and enjoyment of certain ocean shorelines and dunes,

forested areas, fresh water lakes and recreational facilities..."

The 1979 Dunes Plan and the 1994 Dune Plan provided open

riding opportunities, but established restrictions for motorized

use in vegetated areas. Those vegetated areas within

motorized areas are allocated as Management Area 10 (C) in

the 1994 Dunes Plan. 

The 1994 Dunes Plan was prepared according to Secretary of

Agriculture regulations (36 CFR 219) which are based on the

Forest and Rangeland Renewable Resources Planning Act

(RPA) as amended by the National Forest Management Act of

1976 (NFMA). This plan was also developed in accordance

with regulations (40 CFR 1500) for implementing the National

Environmental Policy Act of 1969 (NEPA). The Dunes Plan

guides resource management activities and establishes

standards and guidelines for the Oregon Dunes NRA.

This Plan describes the goal of MA 10 (C) "to protect existing

vegetated areas while providing controlled opportunities for

OHV riding and travel on designated routes through the area

to reach the beach and other areas which are open to OHV

use." (Dunes Plan, III-36).

Please refer to Response #9 for a discussion of the

development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 487 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug The management of and the designation of, MA 10(C) and MA 

10(8} trails must be in the context of the original Act.

Management Areas, including MA 10 (B) and MA 10 (C), were

described in the 1994 Dunes Plan. The Dunes Plan was

prepared according to Secretary of Agriculture regulations (36

CFR 219) which are based on the Forest and Rangeland

Renewable Resources Planning Act (RPA) as amended by

the National Forest Management Act of 1976 (NFMA). The

Plan was also developed in accordance with regulations (40

CFR 1500) for implementing the National Environmental

Policy Act of 1969 (NEPA). The Dunes Plan guides Forest

Service management and protection of the ODNRA. It was

developed with the participation and assistance of interested

members of the public. It provides guidance and direction to

ensure that the Forest is fulfilling its public trust in a manner

that meets the intentions Congress had in mind when it

acknowledged the ODNRA legislatively. The Act (H.R. 8763)

established the ODNRA to "provide for the public outdoor

recreation use and enjoyment of certain ocean shorelines and

dunes, forested areas, fresh water lakes, and recreational

facilities...and the conservation of scenic, scientific, historic,

and other values contributing to public enjoyment..."

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 488 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug The legislative History was clear when Congress noted that 

the lack of vegetation in some areas is a definite recreational 

asset and that artificial plantings of sand-stabilizing plants are 

a detriment.[...]Since the Draft EA discussion relative to the 

impact of ATV use on vegetated trails does not distinguish 

between (a) vegetative buffers for developed facilities, (b) 

damage to fragile pioneering plant communities, or, (c) the 

benefit of buffers between active dunes and improved 

property, the proposed actions are inconsistent with the Act. 

It is only those historic and cultural routes that are 

inconsistent with this three part test that should be closed in 

the MA 10(C) context. Trails that do not fall within this 

category should be designated for access to the beach.[...]

The proposed action does not consider the question of 

whether these routes through the MA 10(C) areas are 

onsistent with Congress' recognition that additional roads and 

facilities would be necessary - nor does it consider how other 

forms of control measures and management techniques would 

allow these routes to be left open while meeting the 

objectives of Congress. The goal of minimizing impacts must 

be read in the context of the entire legislation not just the MA 

10(C) goals.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Robertson, Doug Douglas County agrees with the Forest Service that historic 

routes that connect sand camping areas and 

private/state/county in-holdings to the open riding areas be 

classified as open for ATV use.

Thank you for your comment.

Robertson, Doug Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 489 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The goal of minimizing impacts must be read in the context of 

the entire legislation. Since there is a significant disparity 

between the Act's anticipated economic outputs and the 

actual outputs, the Forest Service should reexamine the 

economics with a methodology that actually examines the 

differences rather than assume no ability to distinguish 

between alternatives.

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 490 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

were run today.

Robertson, Doug The Oregon Dunes NRA is one of the major economic driving 

forces within coastal Douglas County.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 491 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Robertson, Doug It is questionable whether invasive species risk is in fact a true 

driving issue that allows separation between the alternatives. 

Further, based on Douglas County's experience in the 

management of invasive aquatic species, a management 

technique that can greatly aid in reducing invasive species is 

the installation of vehicle washing facilities. In this case, 

washing facilities at public and private campgrounds and trail 

heads would be one effective tool that would reduce the risk 

across all alternatives.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 492 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug Douglas County is concerned that the spread of vegetation 

into areas that were once open sand is a new circumstance 

that justifies redesignating these vegetated trails as MA 10(8) 

open riding.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 493 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Robertson, Doug Further, your proposal to close trails that are in areas that 

were open sand in the 1970's is inconsistent with the 

legislative history accompanying the Act.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Robertson, Doug Measuring rider safety solely in the context of injuries 

reported to medical facilities is one way to monitor safety; 

however, there are other more sensitive ways to measure 

rider safety that would allow comparison between 

alternatives. For example, the interaction rate between riders 

would be a reliable measure of safety - namely the less 

interaction the less likely for rider to rider accidents. Further, 

the Douglas County Sheriff has indicated that there is 

statistical data that tracks injuries to OHV riders within the 

riding areas. We recommend that the ROD and final EIS 

incorporate this information which is available through the 

local law enforcement agencies. We suggest the Forest 

Service reexamine the rider safety issue in both of these 

contexts.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Robertson, Doug All alternatives should be explored in the context of 

minimizing management and enforcement costs. If the 

selected alternative cannot be logically, economically or 

practically enforced, then it does not achieve the goals ofthe 

Oregon Dunes NRA.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 494 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 495 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Robertson, Doug The final decision should recognize the historic overlook areas 

on the western side of Clear Lake in the Middle Riding Area. 

These areas should be classified as designated open trails 

under 10(C) and maintained in their historic primitive riding 

condition.[...]In the Middle Riding Area, the connecting trails 

at Banshee Hill and to the immediate south thereof should be 

classified as either 10(8) areas or as 10(C} designated as 

open areas.

The 1994 Dunes Plan directs that trails be designated within

MA 10 (C) in order to connect open riding areas and to

connect open riding areas to the beach. Trails within MA 10

(C) that lead to a viewpoint do not fit the direction for

designating routes in MA 10 (C). Views of Clear Lake can be

had from the open riding areas between the forested fingers.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 496 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Rowland, Lance & Barbara The main issue of non-native vegetation still has not been 

addressed....what is the plan to control and/or remove nonnative?

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Rowland, Lance & Barbara we see so little what the impacts to the countries (Lane, 

Douglas & Coos) would be that it is a mute point. Did you 

consult with all 3 counties and if so what were their responses

[...]The issue of the 3 counties’ inputs needs to be addressed 

and documented.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Rowland, Lance & Barbara In the DEIS the FS states that there was little economic 

impact. We would like to know who or where you got your 

information from.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 497 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 498 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Rowland, Lance & Barbara The working group’s document and the DEIS were both 

prepared by the Forest Service with two different economic 

impacts?

The working group report is not a Forest Service document. In

2009, an independent working group comprised of people

with varied interests in the Dunes was formed to develop

ideas for how to designate routes and areas in Management

Area 10 (C). An independent facilitator assembled the group,

led meetings and submitted a final report on behalf of this

independent group. Throughout the more than one year that

the group met, meetings were held that were open to the

public. Forest Service officials attended and were available to

answer questions from the public. 

Rowland, Lance & Barbara We feel this whole document is totally flawed and needs to be 

discarded. The USFS needs to start over again with data and 

science that is current.

The FEIS adheres to applicable laws, regulations and policies.

Saccato, Lawrence 1. The EIS failed to address or consider the expansion of the 

trail system back to its original area as designated in the 1972 

Public Law 92-260 the Act creating the Oregon Dunes National 

Recreation Area. The area originally established consisted of 

28,900 acres. To date there only remains II ,435 acres open 

to the offroad travel which is a reduction of 60% of original 

intended use.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 499 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 500 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 501 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 502 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 503 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Saccato, Lawrence 2. The 1994 Forest Plan required the identification of the 

routes to be mapped within 3 years which was not completed. 

The failure to meet this requirement, although may not be 

fatal, is a serious deficiency to the Forest Management Plan.

Due to staffing and budget constraints as well as other work

priorities, additional routes were not designated within three

years of the 1994 Dunes Plan. This project redeems the

Forest Service's responsibliity to implement the Dunes Plan,

the Travel Management RUle, and Executive Order 11644 by

designating routes within MA 10 (C). 

Saccato, Lawrence 3. The EIS failed to consider changing all ofthe IO(c) areas to 

10(b) areas to open riding designation. This would eliminate 

the mandate of maintaining the trail system required under 

the I 0( c) and expending limited resources.

The purpose and need for this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the

4,455 acres within Management Area 10 (C). MA 10 (C)

consists primarily of vegetated areas in the ODNRA and

restricts the operation of OHVs to designated routes. Some

areas allocated as Management Area 10 (C) were found to

better meet the appearance, conditions and management

objectives of MA 10 (B), which permits open riding. The

predominance of non-native vegetation is one criteria

for proposing to reallocate areas of MA 10 (C). In developing

a range of alternatives to meet the purpose and need various

acreages are proposed for reallocating to open riding.

Alternative 5 proposes the most acres for reallocation (966

acres). 

Areas of MA 10 (C) containing non-native vegetation that were

not proposed for reallocation include areas bordering nonmotorized recreational activities including hiking trails,

campgrounds and lakes, as well as areas along the eastern

edge of the ODNRA from which noise travels into nearby

communities. These exclusions were made to lessen user

conflict resulting from OHV noise.

Saccato, Lawrence 4. The EIS only lightly skimmed the economic impact on the 

surrounding community, both in recreational revenues but 

also the impact on prope1iy values

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 504 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 505 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Saccato, Lawrence 5. The EIS also did not adequately address the original 

legislative intent when Congress created the Oregon Dunes 

National Recreation Area. See § 460z. Establislm1ent

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Saccato, Lawrence I am in hopes that the issues can be resolved administratively 

without any additional reductions to usable areas and the reestablislm1ent the encroachments that have slowly taken

effect to the original area encompassed within the legislative 

act.

H.R. 8763, established the Oregon Dunes National Recreation

Area in order "to provide for public outdoor recreation use and

enjoyment of certain ocean shorelines and dunes, forested

areas, fresh water lakes, and recreational facilities..." Please

refer to Response #142 for a discussion of open dunes in

1972, and 1979 when the first Dunes Plan was released as

compared to current conditions. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 506 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Saccato, Lawrence I encourage you to direct your staff work with the various 

Counties, Associations, Club and individuals in resolving their 

concerns regarding the impacts of the proposed Designated 

Routes Project.

The Forest Service informed Coos, Douglas and Lane

Counties of this project and solicited their input. The

Designated Routes Project scoping letter was mailed to the

Coos, Lane and Douglas County Commissioners on June 9,

2011. The Designated Routes Project Draft Environmental

Impact Statement was sent to the Coos, Lane and Douglas

County Commissioners on October 26, 2012 for the 45 day

public comment period. The public comment period was

extended 45 days and a letter regarding this extension was

mailed to the Coos, Lane and Douglas County Commissioners

on December 6, 2012. The Forest has met with the Coos,

Lane and Douglas County Commissioners and listened to

their concerns.

Sanderson, Rebekah The areas we like are trails that run up a mountain. It has 

several trails the kids can go up and back down.

Thank you for your comment.

Sanderson, Rebekah It is a safe area because we can see if other riders are 

approaching.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 507 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Sanderson, Rebekah Closing these trails will make the area smaller thereby 

creating a greater chance of injuries. We need more areas to 

ride not making our space smaller. DO NOT CLOSE ANY MORE 

RIDING AREAS!

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

sayah, oliver I worry that over time, this

area will continue to decline & will eventually be reduced to 

point

where it becomes unsafe to operate since so many people will 

be using

a relatively small area.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Schrick, Ron I would like to implore you not to close any further riding 

areas at the Oregon Coast. My family and I have been riding 

the dunes for 8 years now. A large majority of that time is 

spent in the trails in Coos Bay, Florence, and Winchester. The 

trails are a great place to teach our kids how to ride. They are 

also very different from open dune riding and they are very 

fun part of the dunes. Please! don't close any further areas.

Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Schwartz, David We really hope you will continue to keep this area at its 

current acreage size as anything smaller will make it more 

congested with riders and it won’t be as rewarding to visit.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 508 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 509 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 510 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 511 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 512 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 513 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Shannon, Anon The Forest Service needs to start from scratch to develop new 

alternatives that will provide maintenance of the OHV trailriding experience.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 514 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Shannon, Anon The value of the trail riding experience is not found by wide 

connecting roads (i.e. whoop roads). The preferred alternative 

(4) closes 62% of trails (84 miles closed out of 135 miles) --- 

unacceptable.[...]The trails in question have been around for 

decades, and while the 10c management plan calls for 

"controlled opportunities" for OHV use, the plan did not 

accommodate the growth of the various OHV users of the 

ODNRA.[...]The Forest Service needs to start over in their 

assessment to develop new alternatives to provide reasonable 

solutions that will accommodate the user experience and 

protect the wetlands and vegetation, which may include 

opening more "open areas" to OHV use, or formulating a plan 

for the creation and maintenance of a designated trail system.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Shannon, Anon The proposed actions are detrimental to the health of the 

sports and economy on the Oregon coast that rely on these 

areas, not to mention the safety and enjoyment of the clubs, 

people, and families that currently use the dunes for 

recreation.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 515 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 516 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Shields, Sandy Vegetation and dune management should dovetail with 

recreation management as part of a coordinated strategy.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Shields, Sandy The Forest Service should create a new or modified planning 

process with alternatives that might help the agency and the 

public to meet the current purpose and needs of the resource 

and community.[...]Please withdraw the current DEIS and 

associated public comment period, conduct supplemental 

analysis and issue a supplemental EIS to include and seek 

input on additional alternatives to those presented in the 

DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 517 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 518 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Slate, Kaili It is for this reason I believe that all 135 miles of illegal trails 

should be closed to OHV riders and the closures should be 

well enforced.[...]Many times while at the dunes I have come 

across illegal camp sites and trails where the ground is torn to 

shreds and strewn with litter. Though I stick to the areas 

closed to OHV riders, it seems their negative influence is 

encroaching more and more on this important and sacred 

landscape.

Closure of all user-developed routes would not meet the

purpose and need for this project. Please refer to the No

Action Alternative that proposes no reallocations to open

riding and no designated routes (DEIS, FEIS, Chapter 2).

Smith, Kathy We ride a lot of the serpentine trails as well as the high

sand.

Alternatives 2, 4, Modified 4 and 5 propose reallocations from

MA 10 (C) to MA 10 (B) to maintain the trail riding experience.

Smith, Kathy The other problem with

the area being made smaller the amount of traffic is more and 

when you put

more people on a smaller amount of trails the possibility of 

injuries' gees up.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Smith, Kathy We do not agree with any of the

proposed alternatives in the DEIS and would ask that the 

Forest Service start

from scratch and develop new alternatives.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 519 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 520 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

Smith, Steven Banshee hill, clear lake trails, and many others in the area I 

am unsure names of. I have been coming here for years to 

get away with, and meet with family. We get beatiful scenery 

and are always respectful always pick up others trash and 

love the nature.

Thank you for your comment.

Soper, Connie I support Option #1, for no additional routes to be authorized 

for ATV use, and for stricter enforcement of existing rules and 

regulations.[...]ATVs are disruptive, smelly and noisy; it is 

unlikely that hikers have the same impact on ATV use that 

ATV users have on hikers[...]I do not support increasing the 

area where ATVs would be allowed.

Thank you for your comment.

Soper, Craig I am firmly opposed to expanding the use of vehicles in the 

dunes and on the beaches.[...]I already find it dangerous and 

unpleasant to have vehicles on the beach.

Oregon State Parks and Recreation manages beaches with

Forest Service jurisdicition begins at the mean high tide

line. This proposal, therefore, does not address OHV use on

beaches because that area is not managed by the Forest

Service. The designated routes proposed and reallocations to

open riding occur within the boundaries of areas managed for

motorized recreation and managed by the Forest Service.

Spielbusch, Larry Open dune riding is both monotonous and dangerous. Most 

injuries suffered at the dunes is due to speed and 

irresponsible use of the OHV in open sand areas.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 521 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Spielbusch, Larry The plants shown in need of protection, as defined in the 

Local Newspaper, are not endangered and don’t require 

protection.

The 1994 Dunes Plan directs that MA 10 (C) be managed to

"protect existing vegetated areas while providing controlled

opportunities for ORV riding and travel on designated

routes" (Dunes Plan, p.III-36). The Dunes Plan directs

managment of MA 10 (C), and therefore, vegetated areas will

be protected and motorized vehicles will only be permitted on

designated routes within MA 10 (C). 

Areas of predominantly non-native vegetation such as

European beachgrass and Scotts broom are proposed to be

reallocated to open riding in alternatives 2, 4, Modified 4 and

5. The intent is of this project is not to protect non-native

vegetation. However, areas of non-native vegetation near

residential areas and areas of non-motorized recreation areas

were not proposed for reallocation to open riding in order to

reduce the impact of noise, thereby reducing user-conflicts.

Spielbusch, Larry The cost to implement this plan as well as to enforce/sustain 

it is far more than is worthwhile.

Trail operation and maintenance will be funded through Forest

Service appropriated funds, recreation fee revenues

generated in the Oregon Dunes NRA, and partnership funds

from the Oregon Parks and Recreation ATV grant

program. Cooperative law enforcement will continue to

address public safety issues. 

Spielbusch, Larry The scope of the project should be that all trials that exist 

now will be allowed to remain and that no new trails will be 

allowed.

Designating all currently existing user-developed routes was

an alternative that was Considered but Eliminated from

Detailed Study (FEIS, p. 62). This alternative does not meet

the direction of the Dunes Plan to designate routes that

connect open riding areas and open riding areas to the

beach nor of 36 CFR Part 212.55(b), which establishes an

objective of minimizing motorized use impacts to the

environment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 522 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Spielbusch, Larry I am opposed to closing existing OHV trails as proposed by 

the Siuslaw Forest Service.

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Spielbusch, Larry The FS is not managing the forest anymore for use by the 

public. You are controlling/regulating its use so the public is 

more and more being restricted from using it.

The 1994 Dunes Plan established management areas with

differing resource emphases within the ODNRA. (Dunes Plan I

-2) including areas that are managed for motorized use such

as MA 10 (C) and MA 10 (B), as well as areas managed for

non-motorized use such as MA 10 (A). This project does not

restrict use by the public in any Management Areas. This

project will, however, define routes within the 4,455 acres MA

10 (C) in which the Dunes Plan directs that motorized vehicles

will be permitted on designated routes only. Alternatives 2, 4,

Modified 4 and 5 propose reallocating areas of MA 10 (C) to

MA 10 (B), thereby increasing areas of open riding.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 523 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Spielbusch, Larry I don’t believe “damage” is being done to the environment if 

the current trail system is left in place.

The 1994 Dunes Plan directs that MA 10 (C) be managed to

"protect existing vegetated areas while providing controlled

opportunities for ORV riding and travel on designated

routes" (Dunes Plan, p.III-36). The Dunes Plan directs

managment of MA 10 (C), and therefore, vegetated areas will

be protected and motorized vehicles will only be permitted on

designated routes within MA 10 (C). 

Areas of predominantly non-native vegetation such as

European beachgrass and Scotts broom are proposed to be

reallocated to open riding in alternatives 2, 4, Modified 4 and

5. The intent is of this project is not to protect non-native

vegetation. However, areas of non-native vegetation near

residential areas and areas of non-motorized recreation areas

were not proposed for reallocation to open riding in order to

reduce the impact of noise, thereby reducing user-conflicts.

Stark, Eileen

The Forest Service should not revise the Dunes Plan to 

expand open riding areas.

Two areas are managed primarily for OHV use at the Oregon

Dunes. Those areas are called Management Area 10 (C)

wherein OHVs are permitted on designated routes only and

Management Area 10 (B), open riding. This project addresses

only Management Area 10 (C). Changes are proposed to MA

10 (C), but no changes are proposed to expand areas

for OHVs into areas that are not currently managed for OHV

use to some degree. The rationale for reallocating areas of

MA 10 (C) to MA 10 (B) includes the predominance of nonnative vegetation. Please refer to Chapter 2 of the DEIS and

FEIS for more information on the rationale for proposals for

reallocations to open riding.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 524 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Stark, Eileen I hate to see any OHV use, but at the very least OHVs should 

allowed ONLY on small areas of open sand, with most open 

sand remaining non-motorized.

The 1994 Dunes Plan describes management areas wherein

OHV use is permitted. Areas of the ODNRA open to cross

country OHV travel are in Management Area 10 (B), which is

primarily open sand. The Dunes Plan also directs that OHVs

will be permitted in some vegetated areas, but restricted to

designated routes in the vegetated areas known as MA 10

(C). The primary purpose of this project is to complete the

designation and development of a comprehensive,

understandable designated OHV route system within the MA

10 (C) areas of the ODNRA, as directed by the 1994 Plan. 

Additionally, some vegetated areas wherein OHVs are

restricted to designated routes are dominated by non-native

vegetation. The intent of this project is not to protect nonnative vegetation. Therefore, four alternatives to the proposed

action suggest reallocating areas of MA 10 (C) to open riding. 

Additionally, some areas currently allocated as MA 10 (C) are

proposed for reallocation to open riding. The rationale for

those reallocations can be found in Chapter 2 of the DEIS and

FEIS.

Conversely, the Dunes Plan also identified areas of open sand

that wherein OHVs would not be permitted. Examples include

the areas west of the Oregon Dunes Day Use Area, and the

Tenmile Creek Research Natural Area (RNA). No reduction in

acres within areas managed for non-motorized activities are

proposed in any of the alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 525 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Stark, Eileen Native vegetation and wetlands must be also protected and 

safeguarded from motorized recreation.

FEIS, Chapter 3, Environmental Consequences, Botanical

Resources Section and Hydrology and Soils Section describe

the direct, indirect and cumulative effects to native vegetation

and wetlands, respectively. Alternative 1, the No Action

Alternative would close all user created trails and Alternative 3

would only designate 3.6 miles of addition trails. These

alternatives would have the least effect to native vegetation or

wetlands.

Stark, Eileen Moreover, the Forest Service should fulfill promises made to 

ecologically restore the Oregon Dunes, which was called for in 

the original 1994 Dunes Plan.[...]The Oregon Dunes are a 

unique and stunningly beautiful natural feature of Oregon. It 

ought to be restored and protected.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Stark, Eileen The Forest Service needs to make a commitment to inform 

OHV riders of designated routes with clear signage, wildlifefriendly fencing, and active enforcement.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 526 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 527 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

violations are handed in a consistent manner.

Stark, Eileen There is no room for off-road vehicles[...]This kind of 

destructive recreation needs to be minimized, not expanded.

Management of the ODNRA is guided by The Dunes Plan

(1994), which amended the Siuslaw National Forest Plan

(1990). A long-term goal of Dunes management is to "provide

a broad range of high-quality recreation settings and

opportunities..." (Dunes Plan, III-1). The Dunes Plan

established separate management areas with differing

resource emphases within the ODNRA. Non-motorized,

dispersed recreation is emphasized in MAs 10 (A), NonMotorized Undeveloped. Motorized use is emphasized in MA

10 (B), open riding; and MA 10 (C), OHVs permitted on

designated routes only. In other management areas,

recreation is not emphasized, but permitted in a manner that is

consistent with management objectives for the area. 

The Forest recognizes that user conflicts exist, but also

recognizes motorized recreation as a legitimate use of the

ODNRA. No routes or reallocations are proposed near areas

of non-motorized recreation or residential areas to reduce user

-conflicts while continuing to provide opportunities for

motorized recreation.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 528 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Stark, Eileen The erosion, exhaust, noise pollution, and damage caused to 

plant and animal life by off-road vehicles and other thrillcraft 

at the Oregon Dunes, and elsewhere, is well documented.

Please refer to the DEIS and FEIS for a discussion of the

affected environement and direct and indirect impacts of the

alternatives on recreation and user conflicts, botany, and

wildlife.

Stock, Chas I for one would like to make sure that no expansion of an 

already existing environmentally destructive activity gets the 

green light.

Pleaser refer to Alternative 1, No Action, which proposes no

additional designated routes and no reallocations to open

riding.

Stock, Chas Let's start thinking about how to peacefully co-exist with our 

precious coastal dunes rather than submitting to the interests 

of the ORV users and ORV industry. We need to have at least 

some places where we can appreciate that habitat without 

listening to the incessant whine of those thrill seekers.[...]ORV 

use in the dunes is about the most disruptive thing I've ever 

had the displeasure of experiencing in the outdoors in my 

entire life.

Management of the ODNRA is guided by The Dunes Plan

(1994), which amended the Siuslaw National Forest Plan

(1990). A long-term goal of Dunes management is to "provide

a broad range of high-quality recreation settings and

opportunities..." (Dunes Plan, III-1). The Dunes Plan

established separate management areas with differing

resource emphases within the ODNRA. Non-motorized,

dispersed recreation is emphasized in MAs 10 (A), NonMotorized Undeveloped. Motorized use is emphasized in MA

10 (B), open riding; and MA 10 (C), OHVs permitted on

designated routes only. In other management areas,

recreation is not emphasized, but permitted in a manner that is

consistent with management objectives for the area. 

The Forest recognizes that user conflicts exist, but also

recognizes motorized recreation as a legitimate use of the

ODNRA. No routes or reallocations are proposed near areas

of non-motorized recreation or residential areas to reduce user

-conflicts while continuing to provide opportunities for

motorized recreation.

Stoller, Michelle Coupled with more and more restrictions on our ability to 

enjoy what is in essence already ours, the fact that closing 

these parks to ATV use is absurd.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 529 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Strutz, Jeffrey The timing of this project is suspect since a Forest revision is 

scheduled for 2014.

At one time the Siuslaw National Forest was to begin Forest

Plan revision in 2009, which was updated to 2010, and then

2011 and then 2014, but now the Siuslaw is not

scheduled. The current schedule for Forest Plan revisions in

Region 6 (Oregon and Washington) is: Malheur, Umatilla and

Walla-Whitman – on-going, Okanogan-Wenatchee, Colville –

on-going, Deschutes – to begin in 2014, Ochoco-FremontWinema – to begin in 2015, Rogue River-Siskiyou to begin in

2016. No other Forests have been scheduled.

Tepfer, Gary I am now asking the Forest Service to not go back on their 

1994

management plan, but instead to enforce protections of those 

areas

that were supposed to remain free of motor vehicles.[...]The 

impact of the motor

vehicles, especially the noise, the messy campsites and the 

maze of

trails ruined the natural beauty and the experience of being 

there.

An enforcement plan involving the Off Highway

Vehicle Coordinator and Law Enforcement will be

developed starting in the Spring of 2014. The three

pronged approach to enforcement will include

education, engineering and enforcement. 

Educating the public concerning the upcoming

changes began in 2012. Once a decision is signed, 

educational will become more specific and include

clarifying for the public which user created routes

will be enforced as closed. Public education will

include on the ground contacts from FS personnel

working in the motorized areas including Law

Enforcement Officers and the OHV crew (all of

whom are Forest Protection Officers). Educational

contacts will also include OHV clubs and

organizations, business operating rental businesses

in the ODNRA and other interested stakeholders. 

Engineering has been part of the project design and

will continue throughout implementation of the

project. Many of the areas to be reallocated from

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 530 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

MA 10 C to MA 10 B were designed to take

advantage of natural barriers in anticipation of

implementation. For example, in the North Riding

Area, reallocations A1 is a heavily trailed corridor

between thick vegetation wherein very few trails

exist because establishing a user created route in

those areas has proven not only difficult, but

undesirable. Another example is in the North Riding

Area is A6. This reallocation consists of the heavily

trail edge along a densely vegetated forested area. 

Again, few trails leave A6 and enter the closure

area due to the difficulty of pioneering trails in this

environment. As the project is implemented, field

personnel will identify areas of non-compliance and

move to the next step in engineering, which will be

to employ physical structures which may include

fencing, barricades and signing. The extent of the

engineering approach will depend on the area and

the level of non-compliance.

The final component of implementation will be

enforcement. The goal of enforcement is to gain

compliance. The team that is being assembled will

include those capable of issuing warnings and

citations. Law Enforcement Officers and Forest

Protection Officers have officer discretion in their

approach to violators. Their input will be

instrumental in developing an agreed upon

approach to enforcement and insurance that

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 531 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

violations are handed in a consistent manner.

Tilton, Mark In general, I feel that Alternative 4 of the Draft EIS strikes the 

most reasonable balance among user groups, environmental 

concerns, and economic impacts

Thank you for your comment.

Tilton, Mark They have few sensitive native species, and most are located 

far enough from non-motorized recreation and residences to 

eliminate conflicts. Increasing legal open riding areas toward 

the center of the riding areas, as far away from other uses as 

possible, appears to me to be the best approach to avoiding 

conflicts.

Please refer to pages 15-16 of the FEIS. The user conflicts

associated with noise were incorporated into the design

of all alternatives in recognition that by not designating routes

and areas near the eastern edge of the ODNRA, noise issues

would not be exacerbated in local communities and impacts to

non-motorized recreation would be reduced.

Tilton, Mark Opening the A2 Dune area near the beach seems OK from the 

Goose Pasture OHV Trail to the south. But allowing open 

riding on the foredune to the north up to the adjacent nonmotorized recreation area results in viewshed degradation and 

increased noise for those users. In addition, use of OHVs on 

the east side of the foredune will increase the noise being 

transmitted to nearby residents in Florence and Glenada.

The northern portion of the proposed A2 reallocation would tie

into an existing designated route along the southern edge of

the South Jetty Road. OHV use of the designated route

accessing the beach from the Goose Pasture staging area will

continue just south, and visible from the South Jetty Road.

Tilton, Mark I strongly support all of the proposed routes in Alternative 4. 

These represent necessary and common sense routes of great 

benefit to the OHV community and minimize conflict with 

other users.

Thank you for your comment.

Tilton, Mark I Strongly Support the proposed closing of User Trails 

adjacent to the Glenada residential area and Cleewox Lake. 

During the working group field trips we directly experienced 

the loud noise and vegetation disturbance that created conflict 

with nearby residences as well as mushroom pickers and nonmotorized recreationists.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 532 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Tilton, Mark I also strongly support the closure of nearly all of the user 

trails close to the South Jetty Road. This helps reduce conflicts 

with non-motorized recreational users and nearby residents.

No designated routes or reallocations from MA 10 (C) to MA

10 (B) along South Jetty Road are proposed in alternatives 1

and 3. In alternatives 2, 4, Modified 4 and 5, A2 is proposed

for reallocation along most of the foredune in the north riding

area. The northern edge of the reallocation would tie

into existing designated route along the southern edge of the

South Jetty Road. In addition, A3 has been expanded in the

modified alternative 4 to include an area near sand camps 1, 2

and 3. All proposed reallocations are inside the South Jetty

designated route are are therefore not anticipated to increase

noise impacts.

Tilton, Mark There is an additional need for Noise Control Measures near 

the South Jetty Road. Since we have moved to Florence, my 

wife and I have often been negatively impacted by the nearby 

presence of the ODNRA.[...]

In addition, I have had countless experiences during birding 

and other nature viewing trips to the South Jetty area where 

the noise from the OHVs severely degraded the experience.

[...]I am disappointed that noise problems appear to have 

been recognized only along the eastern boundary of the North 

Riding Area. There are also severe noise problems along the 

South Jetty Rd that directly affect Florence and Glenada 

residents, as well as all users of the popular non-motorized 

recreational area to the north of this road.[...]

As a part of this program, closing the steep, open sand face 

adjacent to the South Jetty Staging Area to OHV use would 

result in an immediate significant reduction in noise conflicts 

with the city of Florence.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 533 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Tilton, Mark Noise levels have been shown by testing to be significantly 

above allowed levels for years. I would like to see the 

immediate implementation of something like a “Noise Concern 

Zone” in this area. OHV users would be directed to unload 

OHVs and proceed at a moderate speed southward and 

westward into the heart of the ODNRA. I suggest this zone be 

bounded by the South Jetty Road on the North and proceed 

southward to a reasonable distance, primarily based on 

topography, to be determined by the USFS.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Tilton, Mark I am concerned that Sand Camps near Incinerator Road and 

Lagoon Campground and Trail are to be retained. I have been 

with birdwatching groups on more than one occasion walking 

around the Lagoon Trail when our nature viewing experiences 

were completely spoiled by OHV noise on user developed 

trails on the hillside above the Lagoon Trail area.[...]I 

recommend relocating sand camps 28, 29, and 30 somewhere 

away from adjacent non-motorized recreational use that 

includes nature viewing, camping, canoeing, hiking, and 

mushroom picking.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Tilton, Mark I support the reallocation of the A16 area of “Banshee Hill”. 

This is a long-used OHV hotspot that provides diversity to the 

OHV experience and a “hill challenge” for those so inclined. 

The vegetation within the reallocation area has already been 

severely compromised or eliminated by OHV use.

Thank you for your comment.

Tilton, Mark strongly support the closure of other user developed routes 

through the “forested fingers” on the east portion of this 

riding area. This is necessary to protect these unique native 

communities from fragmentation and potential degradation of 

plant and wildlife communities. It is also important to limit the 

introduction of non-native invasive species into these 

communities.

Alternatives 2, 4, Modified 4 and 5 propose reallocating the

popular area known as "Banshee Hill," to open riding. No

alternatives propose designating any other areas or trails

within the forested fingers in the Middle Riding Area.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 534 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Tilton, Mark I can reluctantly support reallocation A18 if it can be assured 

that open OHV riding can be kept behind the top of the 

foredune to provide a noise and visual buffer for nonmotorized users on the beach which is closed to OHV use. 

Allowing open OHV use of this route will require strict 

enforcement to prevent trespass on the closed beach area.

There is no A18, but you may be referring to A16 which,

under the DEIS, would reallocate 132 acres just east of the

foredune in the Middle Riding Area to open riding. In

response to comments regarding enforcement issues and

user conflicts, Alternative 4 was modified to adjust the

western boundary of A16 below the crest of the foredune. 

Tilton, Mark I am concerned about the Proposed Reallocation A5 North of 

Beale Lake. During the working group field trips we noted 

quite a bit of illegal OHV use near Beale Lake. Allowing legal 

open riding in this area may increase unwanted OHV use and 

habitat damage in this sensitive wildlife area (MA 10F).

Engineering improvements have been installed to protect

Beale Lake from motorized activity. In 2009, 145 feet of

fencing was installed along the north side of Beale Lake to

prevent motorized entry. Several post/rail barriers across trails

preventing entry from the west side of the closure were also

installed. Other areas along the west and north are signed as

closed with carsonites. In 2012, the Riley Ranch designated

route was fenced along both sides of the route through the MA

10 (C) area preventing motorized entry into the closure from

the north east of Beale Lake.

turner, steve I support multiple-use management including motorized 

recreation

Thank you for your comment.

Turner, Helen I think closing all these smaller trails will make it unsafe. Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Turner, Helen I’m sure this would have affect on local businesses that relies 

on tourists as well as on

Park Revenue.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 535 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 536 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Turner, Helen To start with please DON’T close the trails that are there! Please refer to Alternatives Considered but Eliminated from

Detail Study in Chapter 2 of DEIS and FEIS for a discussion of

why the alternative to designate all currently existing userdeveloped routes was eliminated from further analysis.

Valdes, Chris My feeling is that this key revenue generating public land 

should be opening more for the future generations not 

closing.

Revenue generation is not a consideration in this project. The

Forest is legally required to designate routes under the 2005

Travel Rule, as well as direction of the 1994 Dunes Plan. 

This project does not prevent access to public land, but is

designating routes and areas open to OHV use within the

4,455 acres of MA 10 (C) wherein OHVs are permitted on

designated routes only.

verbeck, rick We strongly oppose any expansion of the ATV boundaries. In 

particular, we do not want ATV’s on the beach or the four 

dunes south of Winchester Bay.[...]As residents of Reedsport, 

we feel that expansion of the ATV boundaries into this area 

would be a great loss for our community.[...]Please do not 

give ATV users more of the precious area near the beach.

Beaches are not managed by the U.S. Forest Service, but are

managed by the Oregon Department of Parks and Recreation,

therefore no alternatives propose allowing OHVs on the beach

adjacent to the Middle Riding Area near Winchester Bay. A16,

south of Umpqua Parking Lot #3 and east of the foredune is

proposed for reallocation to open riding in Alternatives 4 and

5. The western boundary of this reallocation has been

adjusted to move the area further down the foredune to lessen

user conflicts between OHVs and recreation on the nonmotorized beach. 

verbeck, rick Extending the ATV area to the beach would force these deer 

out of their habitat as well as the many other animals who live 

in this fragile environment.

Deer are not a threatened or endangered species. For

example the state still permits deer hunting and deer habitat

requires no special protection. The endangered species of

note in the project area are snowy plover. Plovers do have

protected habitat in which no changes to allow motorized use

are proposed.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 537 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

verbeck, rick Already the ATV noise is easily heard on the beach. We go to 

the beach early in the morning to avoid the noise from the 

ATV’s.

Enforcement of sound limits at the ODNRA is an ongoing

management priority. Adjusting Management Area 10 (L), the

noise buffer in the north riding area is outside of the scope of

this project, which focuses only on Management Area 10 (C).

Closure of open riding areas in Management Area 10 (B) is

also of the scope of this project.

Walters, Dave adamantly opposed to any more

closures in the Oregon Dunes NRA.

On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Walters, Dave The dunes are a

national draw, and the economic consequences of that need 

to be

considered above many other criteria.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 538 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 539 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

were run today.

Walters, Dave in the dunes with invasive plant species taking over the open

sand, I think the USFS would be well advised to concentrate 

on

restoration.[...]I suggest, even at the possible loss of some of 

the effort

to date, that the process of saving the dunes be started again 

with a

clean slate.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Walters, Dave The shrinkage of open sand areas in the last 40 years has

deprived current and future users of what

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 540 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Watanabe, Bruce First and foremost I consider the ODNRA a unique resource 

and asset. We must do everything we can to preserve it for 

future generations. It is clear fromhistorical aerial photos and 

my discussion with Marty Stein, USFS botanist, that left 

unchecked, the European beach grass and othe rinvasive 

species will eventually obliterate our dunes. Therefore with 

respect to the proposed alternatives any restriction of OHV 

use would potentially allow the further spread of the foredune 

and deflation plain. Mr. Stein agreed that there is some 

evidence that open riding may, in fact, help curtail the spread 

of the non-native plants.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Watanabe, Bruce using resources to patrol/sign designated routes is only valid 

to protect native species such as doug fir, tree islands etc... It 

does not make sense to patrol/restrict riding in the deflation 

plain.[...]I respectfully suggest that designated routes be 

created/patrolled to protect the tree islands/fingers (ie areas 

such as "Banshee hill") but opened up elsewhere to preserve 

our ODNRA.

The Dunes Plan directs managment of MA 10 (C) to "protect

vegetated habitats while providing controlled opportunites for

ORV touring and travel on designated routes." (Dunes Plan, III

-20). Management Area 10 (C) encompasses more than just

the vegetated fingers at Umpqua and tree islands, but also

includes areas such as the deflation plains in the north and

middle riding areas, as well. 

Wells III, Jim

The idea of opening new areas in the ODNRA to motorized 

use because other areas will be closed that never should have 

been impacted by motorized use in the first place reminds me 

of the VERY twisted cries for "balance" by the logging industry 

during the timber wars

No new areas are proposed to be opened to motorized

use. Management Area 10 (C) was zoned in the 1994 Dunes

Plan as an area in which OHVs are permitted on designated

routes. This project will designate routes and areas within MA

10 (C) only.

White, Richard Please withdraw the current DEIS and associated public 

comment period, conduct supplemental analysis and issue a 

supplemental EIS to include and seek input on additional 

alternatives to those presented in the DEIS.

The National Environmental Policy Act provides the Forest

Service guidance on preparation of an Environmental Impact

Statement (EIS). This includes involving the public. The

Notice of Intent to prepare an EIS initiates the scoping process

and provides the public the opportunity to provide the Forest

Service information they may not have considered. This

information should be included in the Draft EIS as an issue (an

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 541 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

unresolved conflict) or to help with disclosing environmental

consequences. For instance, the trail riding experience came

to us loud and clear and was included in the Draft EIS. The

Notice of Availability of the Draft EIS provides for a 45 day

public comment period. Following the comment period the

Forest Service analyzes the comments to discern if there is

any new information that would cause a Supplemental Draft

EIS. After analyzing and responding to the comments, the

Forest sees no need to supplement the Draft EIS. Listed

below is the effort the Forest made to meet the National

Environmental Policy Act.

The The Siuslaw National Forest began seeking information

from the public in regard to the Designated Routes project in

2009, when the Forest hired an independent contractor to

assemble and facilitate a working group of individuals with

varied interests in the Oregon Dunes. In 2010, this working

group provided ideas regarding a system of designated trails

and open riding areas that they believed would meet the 1994

Dunes Plan. The results their work was posted to the Forest

website.

A Notice of Intent to prepare an EIS was published in the

Federal Register on June 24, 2011. A scoping letter was

mailed to approximately 150 individuals, groups and

agencies. Over 800 scoping comment letters were received,

as well as petitions containing nearly 6,500 signatures and

comments. 

A Notice of Availability of the Draft EIS was published in the

Federal Register on October 24, 2012. The Draft EIS was

posted to the Forest website. The Forest sent about 700

letters and emails announcing the Notice of Availability of the

Draft EIS with a web link to the project on the Forest Service

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 542 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

website. The letter further stated that printed copies would be

made upon request. The Draft EIS was placed in public

libraries and was available at the Forest Service offices in

Reedsport, Waldport and Corvallis. The Forest hosted an

open house in Reedsport on November 17, 2012. At the

request of the public the comment period was extended an

additional 45 days. Another open house was held in Eugene

in January, 2013. Other meetings with interested members of

the public took place in Corvallis in December, 2012 and in

Roseburg in January, 2013. In addition the Forest met with the

Coos, Douglas, and Lane County Commissioners. The Forest

has received approximately 1310 comments.

White, Richard OHV recreation has already been "minimized"[...]The DEIS 

continues to wrongly fixate on restricting OHV access rather 

than a logical and more legally defensible focus on broader 

management issues.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 543 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 544 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 545 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 546 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 547 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

White, Richard Vegetation and dune management should dovetail with 

recreation management as part of a coordinated strategy.[...]

The project should address active and effective vegetation 

management alternatives, which can complement, and 

potentially be enhanced by, effective recreation management.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

White, Richard The purpose and need should have been broadened to 

address the legislative intent of the original National 

Recreation Area Act.[...]The Forest Service should create a 

new or modified planning process with alternatives that might 

help the agency and the public to meet the current purpose 

and needs of the resource and community.

The 1990 Siuslaw Forest Plan as amended by the 1994

Dunes Plan addresses the legislative intent of the National

Recreation Act. A portion of the Dunes Plan, Management

Area 10 (C) was not fully implemented. The 2005 Travel

Management Rule changed National Forest's from being open

to motorized travel unless designated closed to being closed

unless designated open. The Travel Management rule

required National Forests to designate roads, trails and areas

open to motorized travel. Management Area 10 (C) - ORVs

on Designated Routes only, had some motorized trails

designated, but many routes were not designated. The

purpose and need of the FEIS is to correct this. The FEIS

analyzed not only routes to designate, but areas that could be

rezoned to open areas for motorized travel.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 548 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

White, Richard In short, the Oregon Dunes present a unique situation where 

active san d dunes should be a desired condition and 

encroachment of non-native vegetation is a "significant issue" 

that must be addressed.

Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

White, Richard The DEIS is fatally flawed since it is based on the 1994 Dunes 

Plan, which was created without legally required input from an 

NRA advisory council. Also, the 1994 Plan is well beyond its 

useful period of 10-15 years as identified within the plan. The 

plan also states that the Forest Supervisor shall review the 

plan every five years to determine if conditions or public 

demands have changed significantly.[...]Users will see this as 

an ongoing effort to restrict OHV use based on the illegal 

1994 Plan.

The advisory council required in the bill to establish the

Oregon Dunes National Recreation Area was terminated by

Forest Service Chief John McGuire, effective on June 10,

1977, in accordance with the provisions of the federal

Advisory Committee Act (FACA) of 1972 (Public Law 92-463).

The Dunes Plan was prepared according to Secretary of

Agriculture regulations (36 CFR 219) which are based on the

Forest and Rangeland Renewable Resources Planning Act

(R_A) as amended by the National Forest Management Act of

1976 (NFMA). The Dunes Plan was also developed in

accordance with regulations (40 CFR 1500) for implementing

the National Environmental Policy Act of 1969 (NEPA).

White, Richard In 1972, approximately 28,000 acres were open for legal OHV 

use. After implementation of the 1979 ODRNA Management 

Plan, the acreage available for OHV use was reduced, by 

about 47%, down to 15,000 acres. When the 1994 ODNRA 

Management Plan was adopted, the acreage available for 

open riding was reduced significantly to 5,930 acres.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 549 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 550 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 551 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 552 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 553 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

White, Richard Between 1972 and 2011, the acreage available for open OHV 

use has been reduced from 28,000 acres down to just below 

6,000 acres. Just 20 percent of the NRA is available for legal 

OHV use today.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 554 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 555 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 556 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 557 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 558 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

White, Richard The Forest Service needs to start from scratch to develop new 

alternatives that will provide maintenance of the OHV trailriding experience. The value of the trail riding experience is 

not found by wide connecting roads (i.e. whoop roads).[...]As 

previously stated the trails the trails subject to closure are 

used not only for access and connection to campsites but also 

enjoyment.[...]They also provide a safer place for our families 

to ride at a slower place, with less distractions, apart from the 

open sand.[...]I firmly, yet respectfully, request that these 

closures be stopped and that new alternatives be developed 

that maintain the unique trails of the Oregon Dunes National 

Recreation Area.

During the scoping process for our original proposed action in

2011, we received numerous comments that trail riding is a

valued recreational activity for OHV riders on the Dunes. In

response to those public scoping comments, the Forest

developed additional alternatives that increased the

reallocation of areas from MA 10 (C) to MA 10 (B) in order to

provide trail riding opportunities in areas that contained

predominantly non-native vegetation. The 1994 Dunes Plan

directs the Forest to designate routes to provide travel

between open riding areas and to provide travel from open

areas to the beach. The routes proposed for designation

would meet this objective. The proposed areas for

reallocation to open riding as MA 10 (B) would provide a

trailing riding experience on unmaintained trails within

vegetated areas. Please refer to FEIS, Chapter 3, Recreation

section for further information on the acknowledged value of

trail riding and the incorporation of that valued recreational

experience in the development of alternatives.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 559 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

White, Richard Closing these trails means that all riders will be made to 

compete for even less riding area; younger or less experience 

riders with smaller vehicles will be made to compete with 

experienced riders with much larger vehicles; noise will be 

concentrated; the risk of accidents will increase; and the 

unique experience of the Oregon Dunes will be lost.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Noise impacts are not expected to increase because no routes

or areas are proposed for motorized use along the eastern

side of the riding areas. Most noise impacts that affect nonmotorized recreation and residential areas are the result of the

topography and prevailing winds that funnel noise from the

exposed eastern portions of the ODNRA.

Alternatives 2, 4, Modified 4 and 5 propose designating areas

to provide a trail riding experience in addtiion to designated

routes in response to public comments that riders value not

only the open dune riding experience, but also trail riding that

can not be fulfilled on designated routes.

White, Richard trail closures proposed in theses options will mean that access 

will be restricted or eliminated to officially established and 

popular campsites like those along Incinerator Road, for 

example.

Alternatives 2, 4, Modified 4 and 5 would maintain access to

all existing designated sand camps. Access to existing

designated sand camps along the Incinerator designated route

are not impacted by any of the alternatives. Additionally,

proposed routes and reallocations would provide access from

sand camps along the Incinerator route to open sand, which

does not currently exist.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 560 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

White, Richard Finally closing these trails will ensure that invasive plants 

continue to spread leading to more closures, much like they 

already have.

Please refer to DEIS and FEIS, Chapter 3, Botanical

Resources for a discussion of invasive species risk.

White, Richard By continuing to insist on closing these trails, it will only lead 

to more disgruntled OHV users who will take their money 

elsewhere.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 561 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

White, Richard Additional closures of the Oregon Dunes National Recreation 

Area to OHV use are not acceptable.

The alternative to designate all existing userdeveloped routes was considered but eliminated

from detailed study. (DEIS, FEIS, Chapter 2)

White, Richard I encourage you to stop any further closures, reclassify many 

of the 10c areas (especially those overrun by invasive plants) 

to 10b, and work with, instead of against, the OHV community 

who is willing to help.

Alternatives 2, 4, Modfified 4 and 5 in the DEIS and FEIS

propose to reallocate areas of MA 10 (C) to open riding based

on several factors, including the predominance of non-native

vegetation.

White, Richard the claims that closures won't negatively effect the economies 

of the coast who rely on OHV tourism, are also false. They 

already have. Not only in direct lost revenue but also in the 

negative public relations and hostile attitudes toward OHV 

recreation that these closures have conveyed.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 562 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 563 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

White, Richard 10c should never have been used to "protect" any of the nonnative and invasive weeds.[...]OHV activity has slowed 

invasive vegetation. Thus OHV areas are the few that still 

have significant open sand.

The 1994 Dunes Plan directs that MA 10 (C) be managed to

"protect existing vegetated areas while providing controlled

opportunities for ORV riding and travel on designated

routes" (Dunes Plan, p.III-36). The Dunes Plan directs

managment of MA 10 (C), and therefore, vegetated areas will

be protected and motorized vehicles will only be permitted on

designated routes within MA 10 (C). 

Areas of predominantly non-native vegetation such as

European beachgrass and Scotts broom are proposed to be

reallocated to open riding in alternatives 2, 4, Modified 4 and

5. The intent is of this project is not to protect non-native

vegetation. However, areas of non-native vegetation near

residential areas and areas of non-motorized recreation areas

were not proposed for reallocation to open riding in order to

reduce the impact of noise, thereby reducing user-conflicts.

White, Richard Restoration of the dunes and of recreation is necessary. Dune Restoration is outside of the scope of this project.

Please refer to Alternatives Considered but Eliminated from

Detailed Study. The Forest is proceeding with two separate

approaches to achieve dunes restoration. The first approach is

engaging OHV recreation partners and conservation partners

on short-term, site specific restoration projects. In the fall of

2013, two site specific restoration projects were implemented.

The two projects are beachgrass removal at Bull Run Staging

Area and scotch broom removal adjacent to Beale Lake. The

second approach is the development of a long-term, broadbased dunes restoration strategy. Conservation and OHV

partners are currently exploring the development of this

strategy.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 564 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

White, Richard OHV use is useful and instrumental in the control of invasive 

plants.

In areas where vegetation has been removed to restore open

sand, we have seen that intensive OHV use has been a

successful deterrent to the reestablishment of vegetation in

small areas but not on a broader scale and not as the sole

means of killing and preventing the reestablishment of

vegetation such as European beachgrass. For further

discussion, please see the DEIS and FEIS, Botany, chapter 3.

White, Richard The FS has already closed nearly 24,000 acres of once open 

recreation area. None of the proposed alternatives return but 

a fraction of once open recreation area. Closing 24,000 acres 

then "giving back" 200 to 400 acres still means that 23,600 

acres of recreation have been lost to closures.

 

In 1972, Public Law 92-260 established the Oregon Dunes

National Recreation Area. Of the 32,150 acres within the

NRA, 21, 632 were National Forest lands as of January 1,

1975. The 1979 Final Environmental Statement Oregon

Dunes National Recreation Area Management Plan proposed

alternative (F) stated, “At present, 91% of the NRA is open to

ORV’s.” It is difficult to determine break down of the

approximately 1,947 acres of what was closed to ORVs prior

to 1979 Plan. One clue is that the 1979 Plan states, “The

Umpqua Dunes Scenic Area is presently closed to ORV’s...”

However, the acreage for the Umpqua Dunes Scenic Area is

not provided. One could assume that a portion of the 1,947

acres could also include the recreation facilities, roads, lakes

and rivers. Regardless, the 1979 Plan seems to state that the

existing condition was that 19,685 acres were open to ORVs. 

The proposed alternative (F) states, “The proposed plan will

revise this to 47%.” This would seem to indicate that 10,167

acres would be open to ORVs. However, it further states, 

“There are approximately 14,000 acres of open sand,

excluding beaches, within the NRA. The proposed ORV area

allocations split this in half; 7,000 acres open and 7,000 acres

closed.” It seems that the remaining 3,167 acres are included

in, “Areas to be designated as open to ORVs with regulation

are: (l) From the South Jetty Siuslaw Road south to the

Siltcoos .Road, with a closure near Honeyman State Park, (2)

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 565 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

A corridor from the proposed Threemile Road parking lot to

the beach, and from the beach to the clam beds on the

Umpqua North Spit, (3) Tenmile Creek vicinity south to the

National Forest boundary below the Horsfall Road, with

closures at the Horsfall Dune, the vicinity of Bluebill

Campground and the Tenmile Creek area and estuary, and (4)

The Forest Service will recommend to the State of Oregon

that the portion of Umpqua Lighthouse State Park lying within

the. NRA be open to ORV's. ORV use of the beach will

continue to be regulated by the State of Oregon. The Forest

Service will recommend to the State of Oregon that the

permanent beach closure south of the Umpqua River South

Jetty be extended to Tenmile Creek.

ORV access will be provided at the following locations:

• South Jetty Big Dune area.

• South Jetty parking lot #1.

• Siltcoos Beach parking lot.

• Tenmile Creek parking lot.

• Hauser parking lot.

• Horsfall Dune parking lot.

• Horsfall Beach parking lot.

If necessary, separate ORV staging area facilities may be

provided in the vicinity of the South Jetty Big Dune, Siltcoos

Creek, and the Horsfall Dune parking lots to minimize user

conflicts.

Within the areas where ORV's will be permitted, the following

guidelines will apply:

1. ORV's will be generally confined to areas of open sand.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 566 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Travel corridors through vegetated areas will be

designated by the Forest Service. In •some cases,

rights-of-way across private lands may be necessary.

2.

ORV’s will be restricted for 200 feet around the shores

of lakes and streams.

3.

Closures may be designated adjacent to campgrounds

and popular day use areas to reduce conflict.

4.

Mufflers will be required to hold noise levels to

acceptable standards.

5.

In the future, permits may be required to limit number of

users to -acceptable levels.

6.

Secretary of Agriculture Regulation 36 CFR 295.6 -

Operating Conditions for Off-Road Vehicles will be

enforced on National Forest land.

7.

Commercial ORV use will continue to be available for the

visitor' s enjoyment within the regulated area.

The remainder of the NRA will be closed to ORV use, except

for administrative purposes, necessary search and rescue

work, beach salvage operations and permitted construction

activities.”

The 1979 further stated, “The Oregon Dunes Advisory Council

had their first meeting on July 15, 1972, the day of the Oregon

Dunes National Recreation Area dedication. They have had

periodic meetings since, keeping completely informed of the

issues and concerns. They became deeply involved in the

planning 'process and the development of the management

plan. By hiking, riding and flying through and over the area,

they became very familiar with the conditions in the area. This

knowledge and involvement was reflected in their voting 13 to

0 to accept the proposed management plan, with the following

amendments: Keep all of Umpqua Lighthouse State Park

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 567 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

open to ORV's, subject to existing State regulations;

recommend to the Forest Service that the plan be so adopted

that it will accommodate a need for a long-term, baseline

data .for security of areas for scientific, scenic, research uses;

and to recommend the Umpqua Dunes Scenic Area and the

area from the Threemile area corridor (clam bed dune buggy

road) south be designated as roadless, undeveloped,

recreation use areas, and the beaches adjacent to these

areas remain subject to State beach regulations.”

The 1994 Final Environmental Impact Statement (FEIS),

Dunes Management Plan states, “There are 31,500 acres

within the NRA boundary. The Forest Service manages

27,450 acres of federally owned lands within the Oregon

Dunes NRA and approximately 1,450 acres of national forest

lands outside the NRA boundary.”

A comparison of the land allocations from the 1979 Plan

described above and represented by Alternative C in the 1994

Plan is not straight forward possibly because the 1979 Plan

did not explicitly display acreages by land allocation. Also, the

forest service now manages about 5,818 more acres than on

January 1, 1975. Summarizing from the 1979 Plan land

allocations described above, it seems as if there were about

7000 acres of open ORV riding on open sand and about 3,167

acres of open ORV riding with regulation. The remaining

11,465 acres were closed to ORV’s. The land allocations from

the 1994 Plan are displayed below for Alternative C (existing

condition) and Alternative F (the selected alternative).

MANAGEMENT AREA/ C (existing)/ F (PA)

10(A) Non-Motorized Undeveloped: 12,810 and 7,830

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 568 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

10(B) ORV Open: 6,090 and 5,930

10(C) ORV Restricted to Designated Routes: 8,220 and 4,455

10(D) Developed Corridors: 876 and 1,050

10(E) Snowy Plover Habitat: 20 and 1,010

10(F) Plant, fish, and Wildlife Habitats: 25 and 3,120

10(G) Wetland Emphasis: 605 and 2,540

10(H) Wildlife and Fish Viewing: 244 and 314

10(I) Vegetation Remova: 10 and 0

10(J) Recommended Wild and Scenic River: 0 and 1,090

10(K) Allocated Research Natural Area: 0 and 1,190

10(L) Noise Reduction Buffer: 0 and 370

TOTAL: 28,900 and 28,900 

wiensz, glenn we had our email hacked we are sending you our new email 

address.

Please don't open the link that was attached with our old 

email.

gbw395@gmail.com

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 569 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Wiley, Brandon opposed to the closure of the already developed trails. On November 9, 2005, the Travel Management Rule was

published in the Federal register. Prior to the Travel

Management Rule, National Forests were open to motorized

travel unless designated closed. Now, under the Travel

Management Rule, National Forests are closed to motorized

travel unless designated open. The Forest is required by law

to complete the designation of trails and routes.

The Oregon Dunes National Recreation Area currently has

about 34 miles of designated trails and about 5,930 acres of

designated areas for open motorized travel. As the Siuslaw

National Forest developed its 2009 Travel Management Plan,

it became apparent that since not all the MA 10 (C) routes had

been designated, some areas within the motorized portions of

the ODNRA were largely inaccessible. 

The 2005 Travel Management Rule closed National Forests to

motorized travel except on designated roads, trails, and areas

that are open to motor vehicles use. This project has five

alternatives to complete trail and area designation within

Management Area 10 (C).

Wiley, Brandon This will make an already crowded riding condition even 

worse.

Rider Safety is discussed in Chapter 1, under "Issues" in both

the DEIS and FEIS. Rider Density can be a partial

determinant of rider safety, but it is not possible to reliably and

accurately predict how any of the alternatives being

considered will affect visitation and thus, rider density. By its

nature, OHV riding can be a high risk outdoor recreation

activity. Given the numerous rider safety variables over which

the Forest Service has no control and the inability accurately

predict future rider density the Forest has proposed

alternatives that it believes have a high potential for rider

safety.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 570 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Wiley, Brandon you should be opening up more trails and make a larger riding 

area.

Expanding open riding areas, MA 10 (B), is outside the scope

of this project. Alternatives 2, 4, Modified 4 and 5 propose

reallocating areas of MA 10 (C) to open riding in MA 10 (B),

thereby increasing the number of acres of open riding in the

ODNRA. Alternatives 2, 3, 4, Modified 4 and 5 propose

designating additional routes.

Wiley, Brandon There is already enough protected dunes to study and enjoy 

in a natural setting.

Thank you for your comment.

Wiley, Brandon when you close enough of the riding area I'm sure people will 

stop riding and supporting local businesses altogether.

Economic impacts are sufficiently examined in the DEIS and

FEIS. Please refer Chapter 3, Economics.

As stated in the economic effects section of the NEPA

document, the findings differ from an Oregon Parks and

Recreation Department report entitled “The Economic Impacts

of Off-Highway Vehicle (OHV) Recreation in Oregon” by Kreg

Lindberg. The major discrepancy between the Forest Service

economic analysis and Lindburg’s is the treatment of

equipment expenditures. In regional economic impact

literature, equipment expenditures are considered to be sunk

costs. Therefore, equipment costs are not usually included in

the analysis. The analysis by the Forest Service does not

include equipment expenditures in the calculation. Lindberg,

on the other hand, includes equipment expenditures. The

Forest Service stands firm in its methods that do not include

the fixed costs of durable goods in the calculation of economic

contributions to of recreation trips to national forests. 

Documentations on the specifics regarding Forest Service’s

NVUM data collection, limitation of results, etc. are available to

the public. All relevant reports (including ‘Spending Profiles of

NF Visitors by Activity’ and ‘Statistical Methods’) can be found

on http://www.fs.fed.us/recreation/programs/nvum/. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 571 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

 

As it turns out, Siuslaw’s Round 3 NVUM was sampled back in

2011. So the results were not’t available at the time of our

analysis (2011). We used round 2 (FY2006). The round 2

numbers were updated (for only those forests have round 3

completed) at some point last year. The round 2 visitation

numbers were reconciled using new findings from round 3.

This means that if you’you have downloaded a round 2 NVUM

report back in 2009, and then download the exact same round

2 report today, they will be different. For the total visits to the

Siuslaw, the reconciled version has less visits. Round 2

visits:1,147,166; Round 2 (reconciled): 946,000; Round 3:

874,000. Visitation numbers dropped, therefore the numbers

reflected in the FEIS are somewhat higher than if the analysis

were run today.

Winquist, John I would strongly support the alternative that maximizes nonmotorized recreation opportunities.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 572 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Winquist, John There is very low compatibility between OHV use and 

pedestrian use.

Management of the ODNRA is guided by The Dunes Plan

(1994), which amended the Siuslaw National Forest Plan

(1990). A long-term goal of Dunes management is to "provide

a broad range of high-quality recreation settings and

opportunities..." (Dunes Plan, III-1). The Dunes Plan

established separate management areas with differing

resource emphases within the ODNRA. Non-motorized,

dispersed recreation is emphasized in MAs 10 (A), NonMotorized Undeveloped. Motorized use is emphasized in MA

10 (B), open riding; and MA 10 (C), OHVs permitted on

designated routes only. In other management areas,

recreation is not emphasized, but permitted in a manner that is

consistent with management objectives for the area. 

The Forest recognizes that user conflicts exist, but also

recognizes motorized recreation as a legitimate use of the

ODNRA. No routes or reallocations are proposed near areas

of non-motorized recreation or residential areas to reduce user

-conflicts while continuing to provide opportunities for

motorized recreation.

Winquist, John There is frequently evidence of OHV activity in the already 

restricted areas.

Non-compliance with laws and regulations occurs with all

types of user groups including hikers, mountain bikers,

equestrians and OHV operators. The percentage of violators

is small within each group. In general, the OHV community

follows laws and regulations on this forest. It is expected that

with increased education, compliance with the new regulations

for closures of undesignated routes and areas will increase.

Wolf, Ron I don't know any of the trails we ride. We usually just follow 

people we go down to the dunes with. Always an enjoyable 

experience. Really love the Oregon dune and trail. Ron

Thank you for your comment.

Wylde, Kimberly give them as little access to land to ride on as possible and 

very steep fines if laws are disobeyed.

Thank you for your comment.

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 573 of 574 9/16/2014 11:17:59 AM
Author(s) Comment Response

Wylde, Kimberly I find all off road vehicle usage to be very destructive, and 

very annoying, to the people and to the wildlife, that need 

peace and quite.

Thank you for your comment. Please refer to the wildlife

analysis in Chapter 3 of the FEIS.

Wylde, Kimberly they harm the wildlife and the plants that depend on 

unspoiled land to survive

The 1994 Dunes Plan designated management areas with

differing resource emphases including snowy plover habitat

MA 10 (E), plant, fish and wildlife habitat MA 10 (F), and

wetlands emphasis MA 10 (G). The Forest believes that OHV

use is a legitimate use of the ODNRA and the Dunes Plan

established management areas allowing for this

use, including MA 10 (C), OHVs are permitted on designated

routes. 

Response to Comment (By Comment Author)

Response to Comment (By Comment Author) 574 of 574 9/16/2014 11:17:59 AM